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VICTORION-Spirit: Phase IIIb, multicentre, randomised controlled study to evaluate the implementation of inclisiran sodium in participants with, or at risk of, Atherosclerotic Cardiovascular Disease and elevated Low Density Lipoprotein Cholesterol using a vaccine model in an NHS primary care setting

Northwest Ehealth Limited · Agency/Public Body

In term In term in the September 2026 edition: the latest version runs to 8 January 2040.

Reference
DARS-NIC-421602-N3B0X
Current version
v3.2
Term of current version
29 May 2026 to 8 January 2040
Start date
9 December 2022
Data controller
Sole Data Controller
Commercial purposes
Yes
Sublicensing
No
Files released to date
29

Data controllers

Why the data was released

Objective for processing

The primary objective of this study is to demonstrate superiority of inclisiran +/- behavioural support compared to the patient’s usual lipid lowering drugs + behavioural support in a primary care setting (i.e. the 3 groups of patients described in point 1 above), in reducing the percentage change in LDL-C from baseline to Day 270 in adults with elevated LDL-C.

The secondary objectives of this study are to evaluate user satisfaction/experience and process evaluation for the 3 groups of patients by means of:

- Validated questionnaires to measure patient satisfaction, patient activation and empowerment, and patient adherence to cardiovascular disease self-management

- A process evaluation conducted using the Consolidated Framework for Implementation Research (CFIR) which will explore inclisiran delivery at three levels

- Feasibility and acceptability of delivery models for inclisiran to patients

- Feasibility and acceptability of delivery models for inclisiran to providers

- Wider use of the proposed delivery models across the NHS (outer setting)

- The service costs of each delivery model

- The acceptability and perceived sustainability of patient identification and referral routes

- Serious adverse event profile

NB. Patient activation is a measure of a person's knowledge, skills, and confidence to manage their own health and wellbeing. Patient empowerment is a process through which people gain greater control over decisions and actions affecting their health.

The exploratory objectives of this study are to compare the 3 groups of patients on the following assessments:

- Total lipid profile (total cholesterol, HDL-C, triglycerides), blood pressure, weight, BMI from baseline to end of study visit.

- Healthcare resource utilisation during the period of the study taken from the primary and secondary care EMR e.g. number of outpatient visits, number of hospital admissions, number of A&E visits, number of primary care visits.

- Assessments of treatment simplicity, resources used for treatment, and treatment impact will be made from bespoke questionnaires based on standard questionnaires used in the assessment of diabetes treatments.

Secondary care data from HES is crucial for the complete analysis of the service costs of each model, Healthcare Resource Utilisation (HRU) analysis, and serious adverse event profile for all patients participating in the study.

The project is now complete. Novartis Pharmaceuticals UK Limited would like to retain this Data to ensure reconstruction of the study analysis is possible if required.

No additional data will be requested from NHS England.

This Data Sharing Agreement (DSA) permits processing of the Data for the purpose of secure storage and back up.

This DSA does not permit any further processing that involves analysis or linkage other than for the purpose of verifying findings in line with the original objectives of the study by repeating previous analyses described in this DSA.

Following publication of the study findings, it is possible that the findings will be questioned or challenged by third parties through direct contact with Novartis Pharmaceuticals UK Limited, contact via the publishing journal or an open letter. In such circumstances, Novartis Pharmaceuticals UK Limited may repeat the previously analyses undertaken to verify that the published results were accurate and may write a response to be issued directly to the challenger or published.

Novartis Pharmaceuticals UK Limited may not undertake different analyses to those undertaken during the original analysis.

This DSA does not permit any onward sharing of the Data.

This DSA permits the necessary processing of the Data for the purposes of permanently destroying, deleting or erasing the Data once it is no longer required for the purpose for which it was collected. Once destroyed/deleted or erased, Novartis Pharmaceuticals UK Limited must confirm destruction to NHS England.

If any further data processing is required in addition to the above purposes or if the data needs to be moved to a different location/organisation Novartis Pharmaceuticals UK Limited must submit an Amendment request to NHS England before Data is accessed.

Data from the following NHS England Data will be retained:

- Emergency Care Data Set (ECDS)

- Hospital Episode Statistics (HES) Outpatients (OP)

- HES Admitted Patient Care (APC)

- HES Accident & Emergency (A&E)

The level of the Data being retained will be identifiable. Although the data fields requested are pseudonymised, NWEH hold the personal identifiers for the cohort, and therefore, though no attempt will be made to identify participants, NWEH have the technical ability to identify participants.

The data was minimised as follows:

- Limited to participating patients based on basic demographics (e.g. month and year of birth – to cross reference to primary care data), appointments/attendance/admissions/discharges/periods of care, treatment, diagnoses, and healthcare resource groups. A significant number of events for patients with ASCVD which occur in secondary care are not coded in primary care. These data are required for the calculation of HRU; without secondary care data the full HRU analysis could not be performed. All participating patients have given informed consent.

- The population of 300 patients per arm of the study was chosen as this is the sample size necessary to detect statistically significant differences in outcomes between the three groups.

- Study participants are aged 18 years or older. To apply any further age restriction would undermine the real-world principles of the study.

Data from 5 years prior to enrolment on the study and up to the end of the study is sought to allow a meaningful comparison of pre- and post-enrolment HRU. ECDS does not contain data for the full 5 years, so data from the HES A&E data set is being requested to provide this.

Only basic demographics (e.g. month and year of birth – to cross reference to primary care data), attendance, treatment, diagnoses, investigations, and conditions have been requested. The full range of these data are necessary for a complete HRU analysis.

- Only data for the period 5 years prior to the patient’s date of consent and throughout the course of the study will be required. The first patient was recruited onto the study in July 2021, so HES data sets back to 2016/17 have been selected in this application to accommodate this (i.e. back to at least July 2016). Date of consent will be provided to NHS England, only 5-years of ‘pre-consent’ data for each patient can be delivered. This option is requested in the interest of further data minimisation.

- The patients consented onto the study are from the Greater Manchester (GM) area and are registered with GPs in that area. Secondary care data is, therefore, likely to come from GM hospitals but could come from hospitals in other areas if, for example, patients had unscheduled visits while travelling or had to attend specialist clinics outside GM. Part of the rationale of using patient’s electronic records in a Real-World study such as this is to minimise interaction with patients and reduce any intrusion. No further reduction in the data requested can be made based on geography.

Novartis Pharmaceuticals UK Ltd is the research sponsor and the Controller as the organisation responsible for ensuring that the Data will only be processed for the purpose described above.

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.

Novartis Pharmaceuticals UK Ltd has determined the processing is necessary for its legitimate interests in trying to understand the safety

and efficacy of medicines in development.

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 funding is provided by Novartis Pharmaceuticals UK Ltd.

There is an ongoing collaboration between Novartis and NHS England to improve lipid management in England. The funding for this study is coming from a budget agreed between Novartis and NHSE as part of the collaboration. For regulatory purposes Novartis is the study sponsor and responsible for setting the objectives and the conduct of the study. NHSE had no responsibility or accountability in the development of the study protocol and have had no involvement in the conduct of the study. However, as collaborators NHS E will receive outputs of the study ((e.g., publications, clinical study report and process evaluation reports)” and are disseminated data under Health and Social Care Act 2012 – s261(2)(c).

NorthWest EHealth Limited (NWEH) is a processor acting under the instructions of Novartis Pharmaceuticals UK Ltd. NWEH's role is limited to linking data from the eCRF, HES, and GP systems and delivering it to Novartis in a format specified by Novartis for them to perform their own analysis.

Microsoft Limited provides IT hosting services to NWEH and will store the data as contracted by NWEH.

Wellbeing provides a 3rd party primary care data extraction service which extracts data from GP EMR systems and delivers it to NWEH. It does not process the GP data in any other way and will not process the data requested from NHS England in any way whatsoever.

Novartis are a pharmaceutical company who have an interest in developing therapies for treating and preventing coronary heart disease. Novartis are interested in understanding how best to deliver their proven therapy for lowering LDL-C in a way that increases uptake and improves public health. Access to primary care data from GP EMR systems and secondary care data from HES data sets will allow for a full statistical analysis of HRU. This analysis will a) inform the evaluation of the superiority of inclisiran when delivered using the described model and, hence, support the primary objective of the study, and b) allow evaluation of the service costs of each delivery model and, hence, support this aspect of the secondary objectives of the study.

Processing activities

No data will flow to NHS England for the purposes of this Data Sharing Agreement (DSA).

Novartis Pharmaceuticals UK Limited holds the relevant records from the HES and ECDS datasets. The Data will contain no direct identifying data items but will contain a unique person ID which can be used to link the Data with other record level data already held by the recipient.

No additional data will be disseminated by NHS England for the purposes of this DSA.

This DSA permits processing of the Data for the purpose of secure storage and back up.

This DSA does not permit any further processing that involves analysis or linkage other than for the purpose of verifying findings in line with the original objectives of the study by repeating previous analyses described in this DSA.

This DSA does not permit any onward sharing of the Data with the exception that the Data may be viewed for the purpose of an audit by a regulator such as the Medicines and Healthcare products Regulatory Agency (MHRA).

The Data will be stored on servers at NWEH and Novartis Pharmaceuticals UK Limited.

NWEH stores Data on the Cloud provided by Microsoft Limited.

In the event that the Data needs to be accessed for the purposes of audit or to enable verification of previous findings, the dataset would be transferred back to the [location/servers] with authorisation from the Chief Investigator where it can be accessed by the study statistician only for the purposes of verifying results of previous analyses by rerunning analyses that were previously undertaken. Data would be accessible only for as long as is required to enable verification of the analyses and to write a response as appropriate. Responses will adhere to the rules for small number suppression in the HES Analysis Guide.

The data may not be transferred to any other location and may only be accessed by substantive employees of NWEH and Novartis Pharmaceuticals UK Limited for the purposes described above.

This DSA is required for the following reasons:

(1) The raw datasets (and any associated datasets and syntax files) may need to be accessed for the purpose of audit;

An audit may be required during the period of this DSA. This would involve a systematic and independent review of trial-related activities and documents, to determine whether data were recorded, analysed and accurately reported. Without all the raw datasets this cannot be done.

(2) Further analysis is expected on these datasets in future;

Any further analysis will only take place following an amendment to this Agreement that would allow further processing of the Data.

(3) All pregnancy follow-up data needs to be retained and accessible for at least 25 years after study completion. This requirement would be subject to further data extension requests – no Data will be retained without a DSA being in place.

Expected output

There are several planned reports and publications from this study. The planned activities are outlined below:

- Documents shared by Novartis with NHS England and Academic Health Science Networks (AHSNs) - textual reports with no patient details

- Patient report #1: report on number of patients meeting broad ‘at risk’ criteria who may be eligible for treatment with inclisiran in the study. Completed January 2022

- Process evaluation #1: early insights report based on feed-back from commissioners, patients, and healthcare professionals. Completed January 2022

- Patient report #2: report on number of patients who meet the full inclusion criteria (i.e. are eligible for inclisiran in the study). Completed June 2022

(Note: the above reports haven't used NHS England data, but they do feed into the research as they add background to the research).

- Process evaluation #2: in-depth report based on feed-back from commissioners, patients, and healthcare professionals.

- Full Clinical Study Report: inclisiran efficacy, patient reported outcomes, safety outcomes, patient demographics, process evaluation summary, and HRU (cost) analysis across the delivery methods

- Peer reviewed publications - aggregate data with small numbers suppressed

- Patient Identification and SNOMED codes / national case findings. Submission to Cardiovascular Research

- Study Methodology publication. Submission to British Medical Journal Open

- Patient engagement: Prior to commencement of the trial a patient focus group was set up by NWEH (on behalf of Novartis) to involve patients at the development stage of the process, to help improve and inform the study, as well as providing an opportunity to gain a better understanding of the patient’s needs. In addition, it offered a chance for the protocol to be tested, issues to be identified, and problems to be resolved before a study opened for recruitment. The study concluded overwhelmingly that participants had a positive opinion about the study. In fact, all those interviewed stated they would be interested in taking part in the study if they were offered the opportunity. When discussed with the researcher, the vaccine like model was perceived as a good alternative to their current medications. From questioning, no participants had any major concerns regarding the study design or the drug administration. Novartis will also be sending participants a summary of findings at the conclusion of the study to keep study participants up to date with the study outcomes.

- Data output: Northwest EHealth will produce a dataset of linked data from the eCRF, GP EMR systems, and the HES datasets. This data will be transformed into the standard format required for submission to regulatory authorities for analysis by Novartis. The data will be patient level and pseudonymised but Novartis will not have access to the pseudonymization key or identifiers and cannot re-identify the patients (see ‘Linked data’ under ‘Processing Activities’). This linked data is necessary for the subsequent production of the Full Clinical Report by Novartis (including HRU analysis) for dissemination to NHS England.

To date, three outputs from the SPIRIT program have been published, including two in peer-reviewed journals and one poster at the British Cardiovascular Society.

Expected measurable benefits

Inclisiran is already a proven therapy in lowering cholesterol and is being rolled out across England in a partnership between Novartis and NHS England. The first ‘population health agreement’ was announced in September 2021 between the NHS and Novartis (see https://www.england.nhs.uk/2021/09/nhs-cholesterol-busting-jab-to-save-thousands-of-lives/ and https://www.nice.org.uk/news/article/nice-approves-ground-breaking-cholesterol-lowering-drug-inclisiran ). This is expected to enable an estimated 300,000 patients with high cholesterol and a history of cardiovascular disease to benefit from the proven benefits of inclisiran over 3 years. It is expected that this figure could rise to almost 500,000 people beyond this period; this has the potential to prevent 55,000 heart attacks and strokes, saving 30,000 lives within the next decade.

However, Novartis seeks to explore improved ways of delivering inclisiran that may increase its uptake and, hence, effectiveness. This ground-breaking study is being delivered in a primary care setting using innovative technology to collect healthcare outcomes and safety data. Study intervention has been kept to a minimum to reduce the impact on patients and healthcare practitioners and helping to ensure the findings of the study are relevant in the real-world, everyday setting. The SPIRIT study seeks to investigate the lipid lowering properties of inclisiran +/- behavioural support compared to the patient’s usual lipid lowering drugs + behavioural support in a primary care setting, and to compare the cost to the NHS (across primary and secondary care) of patients from the three cohorts. This, along with the process evaluation, is intended to inform NHS England in the most effective and acceptable (to patients and healthcare professionals) way to progress the national programme in terms of inclisiran delivery.

Benefits reported so far

Findings have been used so far to better understand POCT (point of care testing) and its limitations in trials and routine clinical practice. The use of routine clinical data for trial data capture also produced learnings for the broader health and social care ecosystem.

Datasets on the current version

Legal basis for provision: Health and Social Care Act 2012 – s261(2)(c)

Datasets approved under DARS-NIC-421602-N3B0X-v3.2
DatasetType of dataSensitivity FrequencyConfidential data
Emergency Care Data Set (ECDS) Identifiable Non-Sensitive One-Off Consent (Reasonable Expectation)
Hospital Episode Statistics Accident and Emergency (HES A and E) Identifiable Non-Sensitive One-Off Consent (Reasonable Expectation)
Hospital Episode Statistics Admitted Patient Care (HES APC) Identifiable Non-Sensitive One-Off Consent (Reasonable Expectation)
Hospital Episode Statistics Outpatients (HES OP) Identifiable Non-Sensitive One-Off Consent (Reasonable Expectation)

Files released

Files released counts only files released externally by DARS. Access granted in NHS England's own systems, such as its Secure Data Environment, is not included.

Patient opt-outs were not applied to any of the 29 files released under this agreement, across every version. About opt-outs

No files recorded as released under the current version. 29 were released under earlier versions, shown in the version history.

Version history

The register lists each renewal of this agreement as a separate row. This site has 4 versions.

DARS-NIC-421602-N3B0X-v3.2 29 May 2026 to 8 January 2040
Title
VICTORION-Spirit: Phase IIIb, multicentre, randomised controlled study to evaluate the implementation of inclisiran sodium in participants with, or at risk of, Atherosclerotic Cardiovascular Disease and elevated Low Density Lipoprotein Cholesterol using a vaccine model in an NHS primary care setting
Commercial
Yes
Sublicensing
No
Datasets
4
Files released
0

Datasets: Emergency Care Data Set (ECDS); Hospital Episode Statistics Accident and Emergency (HES A and E); Hospital Episode Statistics Admitted Patient Care (HES APC); Hospital Episode Statistics Outpatients (HES OP)

What changed from DARS-NIC-421602-N3B0X-v2.5

Text removed is struck through; text added is underlined. Unchanged paragraphs are summarised rather than repeated.

Fields changed from DARS-NIC-421602-N3B0X-v2.5
FieldWasBecame
Start date2026-01-092026-05-29

Objective for processing

[50 paragraphs unchanged] Restore PLC provides IT back up services and will store copies of the data. [2 paragraphs unchanged]

Processing activities

[7 paragraphs unchanged] Novartis uses offsite back-up services provided by Restore PLC. [9 paragraphs unchanged]

Unchanged: Expected output, Expected measurable benefits, Benefits reported.

DARS-NIC-421602-N3B0X-v2.5 9 January 2026 to 8 January 2040
Title
VICTORION-Spirit: Phase IIIb, multicentre, randomised controlled study to evaluate the implementation of inclisiran sodium in participants with, or at risk of, Atherosclerotic Cardiovascular Disease and elevated Low Density Lipoprotein Cholesterol using a vaccine model in an NHS primary care setting
Commercial
Yes
Sublicensing
No
Datasets
4
Files released
0

Datasets: Emergency Care Data Set (ECDS); Hospital Episode Statistics Accident and Emergency (HES A and E); Hospital Episode Statistics Admitted Patient Care (HES APC); Hospital Episode Statistics Outpatients (HES OP)

What changed from DARS-NIC-421602-N3B0X-v1.3

Text removed is struck through; text added is underlined. Unchanged paragraphs are summarised rather than repeated.

Fields changed from DARS-NIC-421602-N3B0X-v1.3
FieldWasBecame
Start date2023-02-272026-01-09
End date2025-12-082040-01-08

Objective for processing

Background Elevated low-density lipoprotein associated cholesterol (LDL-C), is one of the major risk factors for coronary heart disease (CHD). Despite advances in treatment, atherosclerotic cardiovascular disease (ASCVD) is the leading cause of death and disability worldwide. Despite the proven efficacy of statins, there is still a considerable variability in individuals to these drugs, even when being treated with a high intensity regime. Furthermore, not all people tolerate statins or are able to take statins at sufficient intensive doses. Therefore, there is a clear unmet medical need for additional options beyond current available oral treatments for the lowering of LDL-C. Inclisiran is a medicine used to lower LDL-C. Raised LDL-C is generally accepted to be an independent risk factor for the development and progression of atherosclerotic cardiovascular disease. Novartis Pharmaceuticals UK Limited holds the UK marketing authorisation for Inclisiran and there is a collaboration agreement in place between Novartis and NHS England. In accordance with the collaboration agreement, it is aimed that 300,000 patients with raised LDL-C will be prescribed Inclisiran over three years so they may benefit from its LDL-C lowering effects. The SPIRIT study, sponsored and funded by Novartis, will inform the national roll out of Inclisiran within a UK primary care setting. While Novartis could benefit financially if Inclisiran is widely prescribed within the NHS, it is expected that this large number of patients will derive benefit in terms of LDL-C reduction. Inclisiran is a treatment for elevated low-density lipoprotein associated cholesterol and can be given in primary care settings as a twice-yearly injection to people with high cholesterol who have already had a previous cardiovascular event to reduce the chances of them having another. It can be used on its own or alongside statins or other cholesterol lowering drugs. Inclisiran works in a new way. It is the first of a new type of cholesterol-lowering treatment which uses ribonucleic acid (RNA) interference (RNAi) to boost the liver’s ability to remove harmful cholesterol from the blood. Ribonucleic acid is a nucleic acid present in all living cells. RNAi refers to a phenomenon where small pieces of RNA can shut down protein translation by binding to and causing the destruction of messenger RNAs that code for those proteins. The efficacy of inclisiran has already been evaluated in three phase III studies (ORION-9, -10, and -11; conducted between November 2017 and September 2019 by The Medicines Company, which was subsequently acquired by Novartis Pharmaceuticals) in patients with ASCVD or ASCVD risk equivalents (e.g. type 2 diabetes mellitus) and/or familial hypercholesterolaemia. These preliminary observations are consistent with the general concept that however LDL-C is lowered, it is thought to result in reduced risk of future cardiovascular events. The overall safety and tolerability profile was generally similar between the inclisiran and placebo groups. However, it is acknowledged that randomised clinical trials, by definition, are highly controlled and enrol a more select patient population than is expected to be prescribed the medicine post-approval. The impact of a new treatment on patient healthcare seeking behaviour and utilisation of local healthcare services is hard to measure from clinical studies with their own schedule of defined visits and procedures, whereby the clinician and patient are following a prescriptive protocol rather than the usual clinical practice. This study seeks to study the effectiveness of inclisiran in a real-world setting, rather than just the efficacy as measured in the previous phase III studies. Study Design This is an implementation research study, the aim of which is to evaluate the practicality and acceptability of administering inclisiran subcutaneously (via injection) in GP practices (in a vaccine-like programme) to consenting participants who have elevated LDL-C and are on established lipid lowering medication or have been recommended lipid lowering therapy by their healthcare provider but are unable to tolerate treatment. 889 participants were randomised onto the trial between July 2021 and March 2022 within the Greater Manchester Area. Recruitment is complete. Participants are split evenly per treatment group into the 3 groups described below at up to 30 primary care centres will be recruited. For clarity, implementation research is commonly defined as the study of methods and strategies to promote the uptake of interventions that have proven effective into routine practice, with the aim of improving population health; how to organise, deliver and maintain an innovative treatment for ASCVD in a primary care setting in a sustainable way. Implementation research seeks to understand and work within real world conditions and is especially concerned with the users of the research and not purely the production of knowledge. In the case of this study, the users are patients and healthcare providers who are, respectively, receiving and administering inclisiran (or managing the administration thereof) within GP practices. The study is based on the following principles: - It is run in the setting where inclisiran is intended to be implemented in clinical practice, with the intention of understanding the effects of innovations within the real-world conditions of everyday clinical practice - Inclusion / exclusion criteria reflect the patient population for whom inclisiran is intended to be used, rather than selecting patients who are suitable for a standard clinical trial - Health delivery context: taking account of institutional and health system contexts – including the viewpoints of various stakeholder including commissioners, system managers and clinicians This study will be conducted using North West E Health’s (NWEH’s) ConneXon clinical trials platform which integrates patient level electronic healthcare record data from primary care, secondary care, and national data sources, to support the integration of ‘real-world evidence’ from individually consented participants. ConneXon has been validated for use in clinical studies. Most of the study data will be extracted directly from the patient electronic medical record (EMR) in order to minimise direct participant contact and maximise the outcomes of interest related to implementation (patients consent to data from their GP and hospital records to be collected). Some study specific data not routinely collected will also be reported by the investigator or delegate in an integrated Electronic Case Report Form (e-CRF) for accuracy and in compliance with regulatory standards. The study is divided into three elements: 1. A prospective phase IIIb intervention with 3 groups of patients: a. Group 1: Participants will continue to receive their existing lipid lowering therapy plus behavioural support b. Group 2: Participants will continue to receive their existing lipid lowering therapy, plus inclisiran injection c. Group 3: Participants will continue to receive their existing lipid lowering therapy, plus inclisiran injection, plus behavioural support. (Behavioural support consists of a regular support telephone call to motivate patients to make effective choices for self-management including behavioural change, goal setting, and empowerment) 2. An observational data assessment utilising the EMR held in primary and secondary care, and analysing data collected within these records during normal clinical practice to examine ongoing healthcare resource utilisation (HRU) and outcomes in the patient cohort 3. A process evaluation that will ascertain the views of patients and healthcare providers about the service they have received or provided and its potential for wider use across the NHS Objective for Processing [16 paragraphs unchanged] Legal Bases The project is now complete. Novartis Pharmaceuticals UK Limited would like to retain this Data to ensure reconstruction of the study analysis is possible if required. Processing of the data is justified under the following UK GDPR Articles: No additional data will be requested from NHS England. 9(2)(j)– Scientific research. Also, improvement in public health due to increased uptake of inclisiran is in the public interest This Data Sharing Agreement (DSA) permits processing of the Data for the purpose of secure storage and back up. 6(1)(f) – It is a legitimate interest of Novartis to investigate means of most effectively delivering a proven therapy. The outcome of a Legitimate Interest Assessment conducted by Novartis: The processing may be within the public interest, as it assists with achieving the clinical study aim of providing new and innovative medicines to patients and improving population health. All parties involved in the processing have an interest in this aim. This DSA does not permit any further processing that involves analysis or linkage other than for the purpose of verifying findings in line with the original objectives of the study by repeating previous analyses described in this DSA. Novartis are a pharmaceutical company who have an interest in developing therapies for treating and preventing coronary heart disease. Novartis are interested in understanding how best to deliver their proven therapy for lowering LDL-C in a way that increases uptake and improves public health. Access to primary care data from GP EMR systems and secondary care data from HES data sets will allow for a full statistical analysis of HRU. This analysis will a) inform the evaluation of the superiority of inclisiran when delivered using the described model and, hence, support the primary objective of the study, and b) allow evaluation of the service costs of each delivery model and, hence, support this aspect of the secondary objectives of the study. Following publication of the study findings, it is possible that the findings will be questioned or challenged by third parties through direct contact with Novartis Pharmaceuticals UK Limited, contact via the publishing journal or an open letter. In such circumstances, Novartis Pharmaceuticals UK Limited may repeat the previously analyses undertaken to verify that the published results were accurate and may write a response to be issued directly to the challenger or published. All participating patients have given informed consent and the study has been approved by an independent Research Ethics Committee. This study does not present any harm to the public. Novartis Pharmaceuticals UK Limited may not undertake different analyses to those undertaken during the original analysis. Data Requested This DSA does not permit any onward sharing of the Data. Emergency Care DataSet (ECDS), Hospital Episode Statistics (HES) Outpatients, Admitted Patient Care, and A+E data is requested so that the patient’s journey across the whole secondary care setting can be analysed. This information, along with primary care data from GPs, will be used to compare the total primary and secondary healthcare resources used by the three patient cohorts and establish if inclisiran and/or behavioural support reduces HRU. This DSA permits the necessary processing of the Data for the purposes of permanently destroying, deleting or erasing the Data once it is no longer required for the purpose for which it was collected. Once destroyed/deleted or erased, Novartis Pharmaceuticals UK Limited must confirm destruction to NHS England. Record level data is required, but no identifiable or sensitive data are being requested. The data requested is minimised to only that of participating patients based on basic demographics (e.g. month and year of birth – to cross reference to primary care data), appointments/attendance/admissions/discharges/periods of care, treatment, diagnoses, and healthcare resource groups. A significant number of events for patients with ASCVD which occur in secondary care are not coded in primary care. These data are required for the calculation of HRU; without secondary care data the full HRU analysis could not be performed. If any further data processing is required in addition to the above purposes or if the data needs to be moved to a different location/organisation Novartis Pharmaceuticals UK Limited must submit an Amendment request to NHS England before Data is accessed. To address the UK GDPR principle of minimisation, only data for the period 5 years prior to the patient’s date of consent and throughout the course of the study will be required. The first patient was recruited onto the study in July 2021, so HES data sets back to 2016/17 have been selected in this application to accommodate this (i.e. back to at least July 2016). Date of consent will be provided to NHS England, only 5-years of ‘pre-consent’ data for each patient can be delivered. This option is requested in the interest of further data minimisation. Data from the following NHS England Data will be retained: Only pseudonymised data is being sought from NHS England, although NWEH supply NHS England with NHS number and date of birth to allow the correct patient cohort to be identified. No sensitive data is requested. - Emergency Care Data Set (ECDS) The population of 300 patients per arm of the study was chosen as this is the sample size necessary to detect statistically significant differences in outcomes between the three groups. - Hospital Episode Statistics (HES) Outpatients (OP) The geography of the study is already restricted to the Greater Manchester area. No further reduction in the data requested can be made based on geography. - HES Admitted Patient Care (APC) Study participants are aged 18 years or older. To apply any further age restriction would undermine the real-world principles of the study. - HES Accident & Emergency (A&E) The level of the Data being retained will be identifiable. Although the data fields requested are pseudonymised, NWEH hold the personal identifiers for the cohort, and therefore, though no attempt will be made to identify participants, NWEH have the technical ability to identify participants. The data was minimised as follows: - Limited to participating patients based on basic demographics (e.g. month and year of birth – to cross reference to primary care data), appointments/attendance/admissions/discharges/periods of care, treatment, diagnoses, and healthcare resource groups. A significant number of events for patients with ASCVD which occur in secondary care are not coded in primary care. These data are required for the calculation of HRU; without secondary care data the full HRU analysis could not be performed. All participating patients have given informed consent. - The population of 300 patients per arm of the study was chosen as this is the sample size necessary to detect statistically significant differences in outcomes between the three groups. - Study participants are aged 18 years or older. To apply any further age restriction would undermine the real-world principles of the study. [2 paragraphs unchanged] The patients consented onto the study are from the Greater Manchester (GM) area and are registered with GPs in that area. Secondary care data is, therefore, likely to come from GM hospitals but could come from hospitals in other areas if, for example, patients had unscheduled visits while travelling or had to attend specialist clinics outside GM. Part of the rationale of using patient’s electronic records in a Real-World study such as this is to minimise interaction with patients and reduce any intrusion. - Only data for the period 5 years prior to the patient’s date of consent and throughout the course of the study will be required. The first patient was recruited onto the study in July 2021, so HES data sets back to 2016/17 have been selected in this application to accommodate this (i.e. back to at least July 2016). Date of consent will be provided to NHS England, only 5-years of ‘pre-consent’ data for each patient can be delivered. This option is requested in the interest of further data minimisation. Organisations involved and their roles: - The patients consented onto the study are from the Greater Manchester (GM) area and are registered with GPs in that area. Secondary care data is, therefore, likely to come from GM hospitals but could come from hospitals in other areas if, for example, patients had unscheduled visits while travelling or had to attend specialist clinics outside GM. Part of the rationale of using patient’s electronic records in a Real-World study such as this is to minimise interaction with patients and reduce any intrusion. No further reduction in the data requested can be made based on geography. Novartis Pharmaceuticals UK Ltd Novartis Pharmaceuticals UK Ltd is the research sponsor and the Controller as the organisation responsible for ensuring that the Data will only be processed for the purpose described above. - Study Sponsor/funding body The lawful basis for processing personal data under the UK GDPR is: - Data Controller Article 6(1)(f) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. - Data Processor Novartis Pharmaceuticals UK Ltd has determined the processing is necessary for its legitimate interests in trying to understand the safety NorthWest EHealth Limited (NWEH)* and efficacy of medicines in development. - Data Processor The lawful basis for processing special category data under the UK GDPR is: Northern Care Alliance NHS Foundation Trust (NCA) 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. - Data Processor The funding is provided by Novartis Pharmaceuticals UK Ltd. - Provide Azure cloud hosting service for NWEH There is an ongoing collaboration between Novartis and NHS England to improve lipid management in England. The funding for this study is coming from a budget agreed between Novartis and NHSE as part of the collaboration. For regulatory purposes Novartis is the study sponsor and responsible for setting the objectives and the conduct of the study. NHSE had no responsibility or accountability in the development of the study protocol and have had no involvement in the conduct of the study. However, as collaborators NHS E will receive outputs of the study ((e.g., publications, clinical study report and process evaluation reports)” and are disseminated data under Health and Social Care Act 2012 – s261(2)(c). Microsoft Limited NorthWest EHealth Limited (NWEH) is a processor acting under the instructions of Novartis Pharmaceuticals UK Ltd. NWEH's role is limited to linking data from the eCRF, HES, and GP systems and delivering it to Novartis in a format specified by Novartis for them to perform their own analysis. - Data Processor Microsoft Limited provides IT hosting services to NWEH and will store the data as contracted by NWEH. - Provide Azure cloud from NCA Restore PLC provides IT back up services and will store copies of the data. Restore PLC Wellbeing provides a 3rd party primary care data extraction service which extracts data from GP EMR systems and delivers it to NWEH. It does not process the GP data in any other way and will not process the data requested from NHS England in any way whatsoever. - Used for data storage / archiving Novartis are a pharmaceutical company who have an interest in developing therapies for treating and preventing coronary heart disease. Novartis are interested in understanding how best to deliver their proven therapy for lowering LDL-C in a way that increases uptake and improves public health. Access to primary care data from GP EMR systems and secondary care data from HES data sets will allow for a full statistical analysis of HRU. This analysis will a) inform the evaluation of the superiority of inclisiran when delivered using the described model and, hence, support the primary objective of the study, and b) allow evaluation of the service costs of each delivery model and, hence, support this aspect of the secondary objectives of the study. Wellbeing Ltd** - Data Processor NHS England (NHSE) - There is an ongoing collaboration between Novartis and NHSE to improve lipid management in England. The funding for this study is coming from a budget agreed between Novartis and NHSE as part of the collaboration. For regulatory purposes Novartis is the study sponsor and responsible for setting the objectives and the conduct of the study. NHSE had no responsibility or accountability in the development of the study protocol and have had no involvement in the conduct of the study. However, as collaborators NHS E will receive outputs of the study ((e.g., publications, clinical study report and process evaluation reports)” and are disseminated data under Health and Social Care Act 2012 – s261(2)(c). *NWEH is wholly directed by Novartis on all aspects of data processing. The eCRF was developed by NWEH based on Novartis' study protocol. The data requested from NHS England and from GPs was that which will allow the objectives of the protocol to be fulfilled. NWEH will link data from the eCRF, HES, and GP systems and deliver it to Novartis in a format specified by Novartis for them to perform their own analysis. **Wellbeing provides a 3rd party primary care data extraction service which extracts data from GP EMR systems and delivers it to NWEH. It does not process the GP data in any other way and will not process the data requested from NHS England in any way whatsoever.

Processing activities

There will be no data linkage undertaken with NHS England data provided under this agreement that is not already noted in the agreement. No data will flow to NHS England for the purposes of this Data Sharing Agreement (DSA). The VICTORION-Spirit: Phase IIIb, multicentre, randomised controlled study is a collaboration between Novartis and NorthWest EHealth; Novartis operate at a more strategic level and ultimately make the decisions about the means and manner of data processing for the purpose of this application. NWEH provide clinical operations and data acquisition/processing services. Specifically: Novartis Pharmaceuticals UK Limited holds the relevant records from the HES and ECDS datasets. The Data will contain no direct identifying data items but will contain a unique person ID which can be used to link the Data with other record level data already held by the recipient. Clinical No additional data will be disseminated by NHS England for the purposes of this DSA. - GP liaison This DSA permits processing of the Data for the purpose of secure storage and back up. - GP Site set-up This DSA does not permit any further processing that involves analysis or linkage other than for the purpose of verifying findings in line with the original objectives of the study by repeating previous analyses described in this DSA. - Patient recruitment and consent This DSA does not permit any onward sharing of the Data with the exception that the Data may be viewed for the purpose of an audit by a regulator such as the Medicines and Healthcare products Regulatory Agency (MHRA). - Patient consultation and administering the investigational product (inclisiran) by NWEH nurses The Data will be stored on servers at NWEH and Novartis Pharmaceuticals UK Limited. Data acquisition/processing Novartis uses offsite back-up services provided by Restore PLC. - Liaison with 3rd parties (including GP system vendors) to secure primary care data NWEH stores Data on the Cloud provided by Microsoft Limited. - Application to NHS England to secure secondary care data In the event that the Data needs to be accessed for the purposes of audit or to enable verification of previous findings, the dataset would be transferred back to the [location/servers] with authorisation from the Chief Investigator where it can be accessed by the study statistician only for the purposes of verifying results of previous analyses by rerunning analyses that were previously undertaken. Data would be accessible only for as long as is required to enable verification of the analyses and to write a response as appropriate. Responses will adhere to the rules for small number suppression in the HES Analysis Guide. - Data quality checks The data may not be transferred to any other location and may only be accessed by substantive employees of NWEH and Novartis Pharmaceuticals UK Limited for the purposes described above. - Linking data and formatting ready for Novartis to analyse This DSA is required for the following reasons: Processing of the data will be made secure, as detailed below: (1) The raw datasets (and any associated datasets and syntax files) may need to be accessed for the purpose of audit; > Patient data is entered into the electronic Case Report Form (eCRF) by research nurses. This is a Web application and is part of NWEH's ConneXon platform. Connexon has been fully validated to host patient data from clinical studies). An audit may be required during the period of this DSA. This would involve a systematic and independent review of trial-related activities and documents, to determine whether data were recorded, analysed and accurately reported. Without all the raw datasets this cannot be done. > Data from GP systems is transferred to NWEH (ConneXon) by Wellbeing via secure File Transfer Protocol (FTP) (2) Further analysis is expected on these datasets in future; > HES data from NHS England is transferred to NWEH (ConneXon) via the SEFT mechanism Any further analysis will only take place following an amendment to this Agreement that would allow further processing of the Data. > ConneXon is hosted within the NHS and benefits from the security that this affords (3) All pregnancy follow-up data needs to be retained and accessible for at least 25 years after study completion. This requirement would be subject to further data extension requests – no Data will be retained without a DSA being in place. > Data is transferred to and from Novartis via their validated Intralinks Web Connect System > All organisations processing the data are on the Data Protection register and have either ISO27001 accreditation, Data Security and Protection Toolkit accreditation, or have provided NHS England with acceptable security documentation. Electronic Case Report Form (eCRF) data: When a patient is consented on to the study, data including basic demographics (e.g. NHS number, age, sex, race/ethnicity) is entered into the study eCRF by a NWEH Research Nurse. The eCRF data is held in the NWEH subscription within the NCA Microsoft Azure tenancy. Each patient is allocated a unique, internal participant identifier (PID). Data from the eCRF is loaded into a study specific database in ConneXon (the trial delivery platform). A list of NHS number study ID's is sent from ConneXon to a staging server within the same secure environment. This list forms the basis of the files (‘consent manifests’) sent to Wellbeing and NHS England for primary care data and secondary care data, respectively. GP data: A consent manifest containing patient’s NHS number, PID, and GP practice code is sent to Wellbeing via Secure File Transfer Protocol (sFTP) daily. Wellbeing use the NHS number and GP practice code to identify the patients and extract their clinical record. In addition to the patients providing informed consent, practices participating in the study also must sign a Wellbeing consent form and activate an electronic agreement within the GP EMR system before any patient data can be extracted from the practice. Wellbeing returns the full clinical record along with the PID (not NHS number) to the NWEH staging server. This data is subsequently loaded into the study database in ConneXon. HES data: A consent manifest containing patient’s NHS number and PID will be sent to NHS England via the Secure Electronic File Transfer (SEFT) portal. NHS England will use NHS number and date of birth, to identify the cohort of patients who have consented within the HES datasets (APC, OP, and AE) and make requested clinical data and the PID (again, not NHS number) available within the SEFT portal where it will be picked up by NWEH and loaded onto their staging server. From there it will be loaded into the study database in ConneXon. Linked data: Under instruction from Novartis, NWEH Database Administrators (DBAs) will link data from the eCRF, GP EMR systems (via Wellbeing), and the HES datasets by PID in ConneXon. NWEH analysts will transform the linked data into the standard format required for submission to regulatory authorities (Study Data Tabulation Model, ‘SDTM’). This dataset will be sent to Novartis analytics division in Switzerland via the Novartis validated Intralinks Web Connect System (IWC) for analysis. Novartis do not require to re-identify patients. The data will be pseudonymised and Novartis will not have access to the pseudonymization key or identifiers and cannot re-identify the patients. It is this linked primary and secondary care data that is necessary to achieve two of the secondary objectives of the study: - Serious adverse event (which could involve hospitalisation) profile - Service cost (HRU) of each delivery model across primary and secondary care Data handling and personnel: data processing is only carried out by substantive employees of the data processor(s) and or data controller(s) who have been appropriately trained in data protection and confidentiality required. Within NWEH and Novartis, the DBAs and analysts who will handle the data undergo mandatory training in data protection and confidentiality. The Novartis Information Management Policy that has been supplied states that "All information management activities must be conducted in accordance with applicable laws, regulations and industry codes, which may be more stringent than the requirements outlined in this Policy." ." Switzerland is subject to an ‘adequacy decision’ by the United Kingdom Government and so is considered to have a suitable level of data protection, equivalent to UK GDPR.

Expected output

[6 paragraphs unchanged] - Process evaluation #2: in-depth report based on feed-back from commissioners, patients, and healthcare professionals. Estimated Q2 2023 [2 paragraphs unchanged] - Patient Identification and SNOMED codes / national case findings. Submission to Cardiovascular Research estimated May 2023 - Study Methodology publication. Submission to British Medical Journal Open estimated May 2023 [2 paragraphs unchanged] To date, three outputs from the SPIRIT program have been published, including two in peer-reviewed journals and one poster at the British Cardiovascular Society.

Benefits reported

Data has not yet flowed from NHS England, therefore analysis has not started and there are no yielded benefits. Findings have been used so far to better understand POCT (point of care testing) and its limitations in trials and routine clinical practice. The use of routine clinical data for trial data capture also produced learnings for the broader health and social care ecosystem.

Changed only in punctuation, spacing or capitalisation: Expected measurable benefits.

Objective for processing

The primary objective of this study is to demonstrate superiority of inclisiran +/- behavioural support compared to the patient’s usual lipid lowering drugs + behavioural support in a primary care setting (i.e. the 3 groups of patients described in point 1 above), in reducing the percentage change in LDL-C from baseline to Day 270 in adults with elevated LDL-C.

The secondary objectives of this study are to evaluate user satisfaction/experience and process evaluation for the 3 groups of patients by means of:

- Validated questionnaires to measure patient satisfaction, patient activation and empowerment, and patient adherence to cardiovascular disease self-management

- A process evaluation conducted using the Consolidated Framework for Implementation Research (CFIR) which will explore inclisiran delivery at three levels

- Feasibility and acceptability of delivery models for inclisiran to patients

- Feasibility and acceptability of delivery models for inclisiran to providers

- Wider use of the proposed delivery models across the NHS (outer setting)

- The service costs of each delivery model

- The acceptability and perceived sustainability of patient identification and referral routes

- Serious adverse event profile

NB. Patient activation is a measure of a person's knowledge, skills, and confidence to manage their own health and wellbeing. Patient empowerment is a process through which people gain greater control over decisions and actions affecting their health.

The exploratory objectives of this study are to compare the 3 groups of patients on the following assessments:

- Total lipid profile (total cholesterol, HDL-C, triglycerides), blood pressure, weight, BMI from baseline to end of study visit.

- Healthcare resource utilisation during the period of the study taken from the primary and secondary care EMR e.g. number of outpatient visits, number of hospital admissions, number of A&E visits, number of primary care visits.

- Assessments of treatment simplicity, resources used for treatment, and treatment impact will be made from bespoke questionnaires based on standard questionnaires used in the assessment of diabetes treatments.

Secondary care data from HES is crucial for the complete analysis of the service costs of each model, Healthcare Resource Utilisation (HRU) analysis, and serious adverse event profile for all patients participating in the study.

The project is now complete. Novartis Pharmaceuticals UK Limited would like to retain this Data to ensure reconstruction of the study analysis is possible if required.

No additional data will be requested from NHS England.

This Data Sharing Agreement (DSA) permits processing of the Data for the purpose of secure storage and back up.

This DSA does not permit any further processing that involves analysis or linkage other than for the purpose of verifying findings in line with the original objectives of the study by repeating previous analyses described in this DSA.

Following publication of the study findings, it is possible that the findings will be questioned or challenged by third parties through direct contact with Novartis Pharmaceuticals UK Limited, contact via the publishing journal or an open letter. In such circumstances, Novartis Pharmaceuticals UK Limited may repeat the previously analyses undertaken to verify that the published results were accurate and may write a response to be issued directly to the challenger or published.

Novartis Pharmaceuticals UK Limited may not undertake different analyses to those undertaken during the original analysis.

This DSA does not permit any onward sharing of the Data.

This DSA permits the necessary processing of the Data for the purposes of permanently destroying, deleting or erasing the Data once it is no longer required for the purpose for which it was collected. Once destroyed/deleted or erased, Novartis Pharmaceuticals UK Limited must confirm destruction to NHS England.

If any further data processing is required in addition to the above purposes or if the data needs to be moved to a different location/organisation Novartis Pharmaceuticals UK Limited must submit an Amendment request to NHS England before Data is accessed.

Data from the following NHS England Data will be retained:

- Emergency Care Data Set (ECDS)

- Hospital Episode Statistics (HES) Outpatients (OP)

- HES Admitted Patient Care (APC)

- HES Accident & Emergency (A&E)

The level of the Data being retained will be identifiable. Although the data fields requested are pseudonymised, NWEH hold the personal identifiers for the cohort, and therefore, though no attempt will be made to identify participants, NWEH have the technical ability to identify participants.

The data was minimised as follows:

- Limited to participating patients based on basic demographics (e.g. month and year of birth – to cross reference to primary care data), appointments/attendance/admissions/discharges/periods of care, treatment, diagnoses, and healthcare resource groups. A significant number of events for patients with ASCVD which occur in secondary care are not coded in primary care. These data are required for the calculation of HRU; without secondary care data the full HRU analysis could not be performed. All participating patients have given informed consent.

- The population of 300 patients per arm of the study was chosen as this is the sample size necessary to detect statistically significant differences in outcomes between the three groups.

- Study participants are aged 18 years or older. To apply any further age restriction would undermine the real-world principles of the study.

Data from 5 years prior to enrolment on the study and up to the end of the study is sought to allow a meaningful comparison of pre- and post-enrolment HRU. ECDS does not contain data for the full 5 years, so data from the HES A&E data set is being requested to provide this.

Only basic demographics (e.g. month and year of birth – to cross reference to primary care data), attendance, treatment, diagnoses, investigations, and conditions have been requested. The full range of these data are necessary for a complete HRU analysis.

- Only data for the period 5 years prior to the patient’s date of consent and throughout the course of the study will be required. The first patient was recruited onto the study in July 2021, so HES data sets back to 2016/17 have been selected in this application to accommodate this (i.e. back to at least July 2016). Date of consent will be provided to NHS England, only 5-years of ‘pre-consent’ data for each patient can be delivered. This option is requested in the interest of further data minimisation.

- The patients consented onto the study are from the Greater Manchester (GM) area and are registered with GPs in that area. Secondary care data is, therefore, likely to come from GM hospitals but could come from hospitals in other areas if, for example, patients had unscheduled visits while travelling or had to attend specialist clinics outside GM. Part of the rationale of using patient’s electronic records in a Real-World study such as this is to minimise interaction with patients and reduce any intrusion. No further reduction in the data requested can be made based on geography.

Novartis Pharmaceuticals UK Ltd is the research sponsor and the Controller as the organisation responsible for ensuring that the Data will only be processed for the purpose described above.

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.

Novartis Pharmaceuticals UK Ltd has determined the processing is necessary for its legitimate interests in trying to understand the safety

and efficacy of medicines in development.

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 funding is provided by Novartis Pharmaceuticals UK Ltd.

There is an ongoing collaboration between Novartis and NHS England to improve lipid management in England. The funding for this study is coming from a budget agreed between Novartis and NHSE as part of the collaboration. For regulatory purposes Novartis is the study sponsor and responsible for setting the objectives and the conduct of the study. NHSE had no responsibility or accountability in the development of the study protocol and have had no involvement in the conduct of the study. However, as collaborators NHS E will receive outputs of the study ((e.g., publications, clinical study report and process evaluation reports)” and are disseminated data under Health and Social Care Act 2012 – s261(2)(c).

NorthWest EHealth Limited (NWEH) is a processor acting under the instructions of Novartis Pharmaceuticals UK Ltd. NWEH's role is limited to linking data from the eCRF, HES, and GP systems and delivering it to Novartis in a format specified by Novartis for them to perform their own analysis.

Microsoft Limited provides IT hosting services to NWEH and will store the data as contracted by NWEH.

Restore PLC provides IT back up services and will store copies of the data.

Wellbeing provides a 3rd party primary care data extraction service which extracts data from GP EMR systems and delivers it to NWEH. It does not process the GP data in any other way and will not process the data requested from NHS England in any way whatsoever.

Novartis are a pharmaceutical company who have an interest in developing therapies for treating and preventing coronary heart disease. Novartis are interested in understanding how best to deliver their proven therapy for lowering LDL-C in a way that increases uptake and improves public health. Access to primary care data from GP EMR systems and secondary care data from HES data sets will allow for a full statistical analysis of HRU. This analysis will a) inform the evaluation of the superiority of inclisiran when delivered using the described model and, hence, support the primary objective of the study, and b) allow evaluation of the service costs of each delivery model and, hence, support this aspect of the secondary objectives of the study.

Expected output

There are several planned reports and publications from this study. The planned activities are outlined below:

- Documents shared by Novartis with NHS England and Academic Health Science Networks (AHSNs) - textual reports with no patient details

- Patient report #1: report on number of patients meeting broad ‘at risk’ criteria who may be eligible for treatment with inclisiran in the study. Completed January 2022

- Process evaluation #1: early insights report based on feed-back from commissioners, patients, and healthcare professionals. Completed January 2022

- Patient report #2: report on number of patients who meet the full inclusion criteria (i.e. are eligible for inclisiran in the study). Completed June 2022

(Note: the above reports haven't used NHS England data, but they do feed into the research as they add background to the research).

- Process evaluation #2: in-depth report based on feed-back from commissioners, patients, and healthcare professionals.

- Full Clinical Study Report: inclisiran efficacy, patient reported outcomes, safety outcomes, patient demographics, process evaluation summary, and HRU (cost) analysis across the delivery methods

- Peer reviewed publications - aggregate data with small numbers suppressed

- Patient Identification and SNOMED codes / national case findings. Submission to Cardiovascular Research

- Study Methodology publication. Submission to British Medical Journal Open

- Patient engagement: Prior to commencement of the trial a patient focus group was set up by NWEH (on behalf of Novartis) to involve patients at the development stage of the process, to help improve and inform the study, as well as providing an opportunity to gain a better understanding of the patient’s needs. In addition, it offered a chance for the protocol to be tested, issues to be identified, and problems to be resolved before a study opened for recruitment. The study concluded overwhelmingly that participants had a positive opinion about the study. In fact, all those interviewed stated they would be interested in taking part in the study if they were offered the opportunity. When discussed with the researcher, the vaccine like model was perceived as a good alternative to their current medications. From questioning, no participants had any major concerns regarding the study design or the drug administration. Novartis will also be sending participants a summary of findings at the conclusion of the study to keep study participants up to date with the study outcomes.

- Data output: Northwest EHealth will produce a dataset of linked data from the eCRF, GP EMR systems, and the HES datasets. This data will be transformed into the standard format required for submission to regulatory authorities for analysis by Novartis. The data will be patient level and pseudonymised but Novartis will not have access to the pseudonymization key or identifiers and cannot re-identify the patients (see ‘Linked data’ under ‘Processing Activities’). This linked data is necessary for the subsequent production of the Full Clinical Report by Novartis (including HRU analysis) for dissemination to NHS England.

To date, three outputs from the SPIRIT program have been published, including two in peer-reviewed journals and one poster at the British Cardiovascular Society.

Benefits reported

Findings have been used so far to better understand POCT (point of care testing) and its limitations in trials and routine clinical practice. The use of routine clinical data for trial data capture also produced learnings for the broader health and social care ecosystem.

DARS-NIC-421602-N3B0X-v1.3 27 February 2023 to 8 December 2025
Title
VICTORION-Spirit: Phase IIIb, multicentre, randomised controlled study to evaluate the implementation of inclisiran sodium in participants with, or at risk of, Atherosclerotic Cardiovascular Disease and elevated Low Density Lipoprotein Cholesterol using a vaccine model in an NHS primary care setting
Commercial
Yes
Sublicensing
No
Datasets
4
Files released
1

Datasets: Emergency Care Data Set (ECDS); Hospital Episode Statistics Accident and Emergency (HES A and E); Hospital Episode Statistics Admitted Patient Care (HES APC); Hospital Episode Statistics Outpatients (HES OP)

What changed from DARS-NIC-421602-N3B0X-v0.13

Text removed is struck through; text added is underlined. Unchanged paragraphs are summarised rather than repeated.

Fields changed from DARS-NIC-421602-N3B0X-v0.13
FieldWasBecame
Start date2022-12-092023-02-27

Objective for processing

[7 paragraphs unchanged] This is an implementation research study, the aim of which is to [37 words unchanged] lowering therapy by their healthcare provider but are unable to tolerate treatment. 805 889 participants were randomised onto the trial between July 2021 and March 2022 [19 words unchanged] described below at up to 30 primary care centres will be recruited. [40 paragraphs unchanged] To address the UK GDPR principle of minimisation, only data for the [5 words unchanged] the patient’s date of consent and throughout the course of the study (i.e. up to the end of December 2022) will be required. The first patient was recruited onto the study in [21 words unchanged] at least July 2016). Date of consent will be provided to NHS Digital, England, only 5-years of ‘pre-consent’ data for each patient can be delivered. This option is requested in the interest of further data minimisation. Only pseudonymised data is being sought from NHS Digital, England, although NWEH supply NHS Digital England with NHS number and date of birth to allow the correct patient cohort to be identified. No sensitive data is requested. [3 paragraphs unchanged] Data from 5 years prior to enrolment on the study and up to the end of the study (end December 2022) is sought to allow a meaningful comparison of pre- and post-enrolment HRU. [12 words unchanged] from the HES A&E data set is being requested to provide this. [20 paragraphs unchanged] - There is an ongoing collaboration between Novartis and NHSE to improve [58 words unchanged] have had no involvement in the conduct of the study. However, as collaborators, NHSE collaborators NHS E will receive outputs of the study (e.g., ((e.g., publications, clinical study report and process evaluation reports). reports)” and are disseminated data under Health and Social Care Act 2012 – s261(2)(c). *NWEH is wholly directed by Novartis on all aspects of data processing. The eCRF was developed by NWEH based on Novartis' study protocol. The data requested from NHS Digital England and from GPs was that which will allow the objectives of the [21 words unchanged] a format specified by Novartis for them to perform their own analysis. **Wellbeing provides a 3rd party primary care data extraction service which extracts [18 words unchanged] any other way and will not process the data requested from NHS Digital England in any way whatsoever.

Processing activities

There will be no data linkage undertaken with NHS Digital England data provided under this agreement that is not already noted in the agreement. [8 paragraphs unchanged] - Application to NHS Digital England to secure secondary care data [5 paragraphs unchanged] > HES data from NHS Digital England is transferred to NWEH (ConneXon) via the SEFT mechanism [2 paragraphs unchanged] > All organisations processing the data are on the Data Protection register and have either ISO27001 accreditation, Data Security and Protection Toolkit accreditation, or have provided NHS Digital England with acceptable security documentation. Electronic Case Report Form (eCRF) data: When a patient is consented on [89 words unchanged] the basis of the files (‘consent manifests’) sent to Wellbeing and NHS Digital England for primary care data and secondary care data, respectively. [1 paragraph unchanged] HES data: A consent manifest containing patient’s NHS number and PID will be sent to NHS Digital England via the Secure Electronic File Transfer (SEFT) portal. NHS Digital England will use NHS number and date of birth, to identify the cohort [44 words unchanged] From there it will be loaded into the study database in ConneXon. [4 paragraphs unchanged]

Expected output

[5 paragraphs unchanged] (Note: the above reports haven't used NHS Digital England data, but they do feed into the research as they add background to the research). [7 paragraphs unchanged]

Benefits reported

Yielded Benefits is not a requirement for new applications. Data has not yet flowed from NHS England, therefore analysis has not started and there are no yielded benefits.

Unchanged: Expected measurable benefits.

Objective for processing

Background

Elevated low-density lipoprotein associated cholesterol (LDL-C), is one of the major risk factors for coronary heart disease (CHD). Despite advances in treatment, atherosclerotic cardiovascular disease (ASCVD) is the leading cause of death and disability worldwide. Despite the proven efficacy of statins, there is still a considerable variability in individuals to these drugs, even when being treated with a high intensity regime. Furthermore, not all people tolerate statins or are able to take statins at sufficient intensive doses. Therefore, there is a clear unmet medical need for additional options beyond current available oral treatments for the lowering of LDL-C.

Inclisiran is a medicine used to lower LDL-C. Raised LDL-C is generally accepted to be an independent risk factor for the development and progression of atherosclerotic cardiovascular disease. Novartis Pharmaceuticals UK Limited holds the UK marketing authorisation for Inclisiran and there is a collaboration agreement in place between Novartis and NHS England. In accordance with the collaboration agreement, it is aimed that 300,000 patients with raised LDL-C will be prescribed Inclisiran over three years so they may benefit from its LDL-C lowering effects. The SPIRIT study, sponsored and funded by Novartis, will inform the national roll out of Inclisiran within a UK primary care setting. While Novartis could benefit financially if Inclisiran is widely prescribed within the NHS, it is expected that this large number of patients will derive benefit in terms of LDL-C reduction.

Inclisiran is a treatment for elevated low-density lipoprotein associated cholesterol and can be given in primary care settings as a twice-yearly injection to people with high cholesterol who have already had a previous cardiovascular event to reduce the chances of them having another. It can be used on its own or alongside statins or other cholesterol lowering drugs. Inclisiran works in a new way. It is the first of a new type of cholesterol-lowering treatment which uses ribonucleic acid (RNA) interference (RNAi) to boost the liver’s ability to remove harmful cholesterol from the blood. Ribonucleic acid is a nucleic acid present in all living cells. RNAi refers to a phenomenon where small pieces of RNA can shut down protein translation by binding to and causing the destruction of messenger RNAs that code for those proteins.

The efficacy of inclisiran has already been evaluated in three phase III studies (ORION-9, -10, and -11; conducted between November 2017 and September 2019 by The Medicines Company, which was subsequently acquired by Novartis Pharmaceuticals) in patients with ASCVD or ASCVD risk equivalents (e.g. type 2 diabetes mellitus) and/or familial hypercholesterolaemia. These preliminary observations are consistent with the general concept that however LDL-C is lowered, it is thought to result in reduced risk of future cardiovascular events. The overall safety and tolerability profile was generally similar between the inclisiran and placebo groups.

However, it is acknowledged that randomised clinical trials, by definition, are highly controlled and enrol a more select patient population than is expected to be prescribed the medicine post-approval. The impact of a new treatment on patient healthcare seeking behaviour and utilisation of local healthcare services is hard to measure from clinical studies with their own schedule of defined visits and procedures, whereby the clinician and patient are following a prescriptive protocol rather than the usual clinical practice. This study seeks to study the effectiveness of inclisiran in a real-world setting, rather than just the efficacy as measured in the previous phase III studies.

Study Design

This is an implementation research study, the aim of which is to evaluate the practicality and acceptability of administering inclisiran subcutaneously (via injection) in GP practices (in a vaccine-like programme) to consenting participants who have elevated LDL-C and are on established lipid lowering medication or have been recommended lipid lowering therapy by their healthcare provider but are unable to tolerate treatment. 889 participants were randomised onto the trial between July 2021 and March 2022 within the Greater Manchester Area. Recruitment is complete. Participants are split evenly per treatment group into the 3 groups described below at up to 30 primary care centres will be recruited.

For clarity, implementation research is commonly defined as the study of methods and strategies to promote the uptake of interventions that have proven effective into routine practice, with the aim of improving population health; how to organise, deliver and maintain an innovative treatment for ASCVD in a primary care setting in a sustainable way. Implementation research seeks to understand and work within real world conditions and is especially concerned with the users of the research and not purely the production of knowledge. In the case of this study, the users are patients and healthcare providers who are, respectively, receiving and administering inclisiran (or managing the administration thereof) within GP practices.

The study is based on the following principles:

- It is run in the setting where inclisiran is intended to be implemented in clinical practice, with the intention of understanding the effects of innovations within the real-world conditions of everyday clinical practice

- Inclusion / exclusion criteria reflect the patient population for whom inclisiran is intended to be used, rather than selecting patients who are suitable for a standard clinical trial

- Health delivery context: taking account of institutional and health system contexts – including the viewpoints of various stakeholder including commissioners, system managers and clinicians

This study will be conducted using North West E Health’s (NWEH’s) ConneXon clinical trials platform which integrates patient level electronic healthcare record data from primary care, secondary care, and national data sources, to support the integration of ‘real-world evidence’ from individually consented participants. ConneXon has been validated for use in clinical studies.

Most of the study data will be extracted directly from the patient electronic medical record (EMR) in order to minimise direct participant contact and maximise the outcomes of interest related to implementation (patients consent to data from their GP and hospital records to be collected). Some study specific data not routinely collected will also be reported by the investigator or delegate in an integrated Electronic Case Report Form (e-CRF) for accuracy and in compliance with regulatory standards.

The study is divided into three elements:

1. A prospective phase IIIb intervention with 3 groups of patients:

a. Group 1: Participants will continue to receive their existing lipid lowering therapy plus behavioural support

b. Group 2: Participants will continue to receive their existing lipid lowering therapy, plus inclisiran injection

c. Group 3: Participants will continue to receive their existing lipid lowering therapy, plus inclisiran injection, plus behavioural support. (Behavioural support consists of a regular support telephone call to motivate patients to make effective choices for self-management including behavioural change, goal setting, and empowerment)

2. An observational data assessment utilising the EMR held in primary and secondary care, and analysing data collected within these records during normal clinical practice to examine ongoing healthcare resource utilisation (HRU) and outcomes in the patient cohort

3. A process evaluation that will ascertain the views of patients and healthcare providers about the service they have received or provided and its potential for wider use across the NHS

Objective for Processing

The primary objective of this study is to demonstrate superiority of inclisiran +/- behavioural support compared to the patient’s usual lipid lowering drugs + behavioural support in a primary care setting (i.e. the 3 groups of patients described in point 1 above), in reducing the percentage change in LDL-C from baseline to Day 270 in adults with elevated LDL-C.

The secondary objectives of this study are to evaluate user satisfaction/experience and process evaluation for the 3 groups of patients by means of:

- Validated questionnaires to measure patient satisfaction, patient activation and empowerment, and patient adherence to cardiovascular disease self-management

- A process evaluation conducted using the Consolidated Framework for Implementation Research (CFIR) which will explore inclisiran delivery at three levels

- Feasibility and acceptability of delivery models for inclisiran to patients

- Feasibility and acceptability of delivery models for inclisiran to providers

- Wider use of the proposed delivery models across the NHS (outer setting)

- The service costs of each delivery model

- The acceptability and perceived sustainability of patient identification and referral routes

- Serious adverse event profile

NB. Patient activation is a measure of a person's knowledge, skills, and confidence to manage their own health and wellbeing. Patient empowerment is a process through which people gain greater control over decisions and actions affecting their health.

The exploratory objectives of this study are to compare the 3 groups of patients on the following assessments:

- Total lipid profile (total cholesterol, HDL-C, triglycerides), blood pressure, weight, BMI from baseline to end of study visit.

- Healthcare resource utilisation during the period of the study taken from the primary and secondary care EMR e.g. number of outpatient visits, number of hospital admissions, number of A&E visits, number of primary care visits.

- Assessments of treatment simplicity, resources used for treatment, and treatment impact will be made from bespoke questionnaires based on standard questionnaires used in the assessment of diabetes treatments.

Secondary care data from HES is crucial for the complete analysis of the service costs of each model, Healthcare Resource Utilisation (HRU) analysis, and serious adverse event profile for all patients participating in the study.

Legal Bases

Processing of the data is justified under the following UK GDPR Articles:

9(2)(j)– Scientific research. Also, improvement in public health due to increased uptake of inclisiran is in the public interest

6(1)(f) – It is a legitimate interest of Novartis to investigate means of most effectively delivering a proven therapy. The outcome of a Legitimate Interest Assessment conducted by Novartis: The processing may be within the public interest, as it assists with achieving the clinical study aim of providing new and innovative medicines to patients and improving population health. All parties involved in the processing have an interest in this aim.

Novartis are a pharmaceutical company who have an interest in developing therapies for treating and preventing coronary heart disease. Novartis are interested in understanding how best to deliver their proven therapy for lowering LDL-C in a way that increases uptake and improves public health. Access to primary care data from GP EMR systems and secondary care data from HES data sets will allow for a full statistical analysis of HRU. This analysis will a) inform the evaluation of the superiority of inclisiran when delivered using the described model and, hence, support the primary objective of the study, and b) allow evaluation of the service costs of each delivery model and, hence, support this aspect of the secondary objectives of the study.

All participating patients have given informed consent and the study has been approved by an independent Research Ethics Committee. This study does not present any harm to the public.

Data Requested

Emergency Care DataSet (ECDS), Hospital Episode Statistics (HES) Outpatients, Admitted Patient Care, and A+E data is requested so that the patient’s journey across the whole secondary care setting can be analysed. This information, along with primary care data from GPs, will be used to compare the total primary and secondary healthcare resources used by the three patient cohorts and establish if inclisiran and/or behavioural support reduces HRU.

Record level data is required, but no identifiable or sensitive data are being requested. The data requested is minimised to only that of participating patients based on basic demographics (e.g. month and year of birth – to cross reference to primary care data), appointments/attendance/admissions/discharges/periods of care, treatment, diagnoses, and healthcare resource groups. A significant number of events for patients with ASCVD which occur in secondary care are not coded in primary care. These data are required for the calculation of HRU; without secondary care data the full HRU analysis could not be performed.

To address the UK GDPR principle of minimisation, only data for the period 5 years prior to the patient’s date of consent and throughout the course of the study will be required. The first patient was recruited onto the study in July 2021, so HES data sets back to 2016/17 have been selected in this application to accommodate this (i.e. back to at least July 2016). Date of consent will be provided to NHS England, only 5-years of ‘pre-consent’ data for each patient can be delivered. This option is requested in the interest of further data minimisation.

Only pseudonymised data is being sought from NHS England, although NWEH supply NHS England with NHS number and date of birth to allow the correct patient cohort to be identified. No sensitive data is requested.

The population of 300 patients per arm of the study was chosen as this is the sample size necessary to detect statistically significant differences in outcomes between the three groups.

The geography of the study is already restricted to the Greater Manchester area. No further reduction in the data requested can be made based on geography.

Study participants are aged 18 years or older. To apply any further age restriction would undermine the real-world principles of the study.

Data from 5 years prior to enrolment on the study and up to the end of the study is sought to allow a meaningful comparison of pre- and post-enrolment HRU. ECDS does not contain data for the full 5 years, so data from the HES A&E data set is being requested to provide this.

Only basic demographics (e.g. month and year of birth – to cross reference to primary care data), attendance, treatment, diagnoses, investigations, and conditions have been requested. The full range of these data are necessary for a complete HRU analysis.

The patients consented onto the study are from the Greater Manchester (GM) area and are registered with GPs in that area. Secondary care data is, therefore, likely to come from GM hospitals but could come from hospitals in other areas if, for example, patients had unscheduled visits while travelling or had to attend specialist clinics outside GM. Part of the rationale of using patient’s electronic records in a Real-World study such as this is to minimise interaction with patients and reduce any intrusion.

Organisations involved and their roles:

Novartis Pharmaceuticals UK Ltd

- Study Sponsor/funding body

- Data Controller

- Data Processor

NorthWest EHealth Limited (NWEH)*

- Data Processor

Northern Care Alliance NHS Foundation Trust (NCA)

- Data Processor

- Provide Azure cloud hosting service for NWEH

Microsoft Limited

- Data Processor

- Provide Azure cloud from NCA

Restore PLC

- Used for data storage / archiving

Wellbeing Ltd**

- Data Processor

NHS England (NHSE)

- There is an ongoing collaboration between Novartis and NHSE to improve lipid management in England. The funding for this study is coming from a budget agreed between Novartis and NHSE as part of the collaboration. For regulatory purposes Novartis is the study sponsor and responsible for setting the objectives and the conduct of the study. NHSE had no responsibility or accountability in the development of the study protocol and have had no involvement in the conduct of the study. However, as collaborators NHS E will receive outputs of the study ((e.g., publications, clinical study report and process evaluation reports)” and are disseminated data under Health and Social Care Act 2012 – s261(2)(c).

*NWEH is wholly directed by Novartis on all aspects of data processing. The eCRF was developed by NWEH based on Novartis' study protocol. The data requested from NHS England and from GPs was that which will allow the objectives of the protocol to be fulfilled. NWEH will link data from the eCRF, HES, and GP systems and deliver it to Novartis in a format specified by Novartis for them to perform their own analysis.

**Wellbeing provides a 3rd party primary care data extraction service which extracts data from GP EMR systems and delivers it to NWEH. It does not process the GP data in any other way and will not process the data requested from NHS England in any way whatsoever.

Expected output

There are several planned reports and publications from this study. The planned activities are outlined below:

- Documents shared by Novartis with NHS England and Academic Health Science Networks (AHSNs) - textual reports with no patient details

- Patient report #1: report on number of patients meeting broad ‘at risk’ criteria who may be eligible for treatment with inclisiran in the study. Completed January 2022

- Process evaluation #1: early insights report based on feed-back from commissioners, patients, and healthcare professionals. Completed January 2022

- Patient report #2: report on number of patients who meet the full inclusion criteria (i.e. are eligible for inclisiran in the study). Completed June 2022

(Note: the above reports haven't used NHS England data, but they do feed into the research as they add background to the research).

- Process evaluation #2: in-depth report based on feed-back from commissioners, patients, and healthcare professionals. Estimated Q2 2023

- Full Clinical Study Report: inclisiran efficacy, patient reported outcomes, safety outcomes, patient demographics, process evaluation summary, and HRU (cost) analysis across the delivery methods

- Peer reviewed publications - aggregate data with small numbers suppressed

- Patient Identification and SNOMED codes / national case findings. Submission to Cardiovascular Research estimated May 2023

- Study Methodology publication. Submission to British Medical Journal Open estimated May 2023

- Patient engagement: Prior to commencement of the trial a patient focus group was set up by NWEH (on behalf of Novartis) to involve patients at the development stage of the process, to help improve and inform the study, as well as providing an opportunity to gain a better understanding of the patient’s needs. In addition, it offered a chance for the protocol to be tested, issues to be identified, and problems to be resolved before a study opened for recruitment. The study concluded overwhelmingly that participants had a positive opinion about the study. In fact, all those interviewed stated they would be interested in taking part in the study if they were offered the opportunity. When discussed with the researcher, the vaccine like model was perceived as a good alternative to their current medications. From questioning, no participants had any major concerns regarding the study design or the drug administration. Novartis will also be sending participants a summary of findings at the conclusion of the study to keep study participants up to date with the study outcomes.

- Data output: Northwest EHealth will produce a dataset of linked data from the eCRF, GP EMR systems, and the HES datasets. This data will be transformed into the standard format required for submission to regulatory authorities for analysis by Novartis. The data will be patient level and pseudonymised but Novartis will not have access to the pseudonymization key or identifiers and cannot re-identify the patients (see ‘Linked data’ under ‘Processing Activities’). This linked data is necessary for the subsequent production of the Full Clinical Report by Novartis (including HRU analysis) for dissemination to NHS England.

Benefits reported

Data has not yet flowed from NHS England, therefore analysis has not started and there are no yielded benefits.

DARS-NIC-421602-N3B0X-v0.13 9 December 2022 to 8 December 2025
Title
VICTORION-Spirit: Phase IIIb, multicentre, randomised controlled study to evaluate the implementation of inclisiran sodium in participants with, or at risk of, Atherosclerotic Cardiovascular Disease and elevated Low Density Lipoprotein Cholesterol using a vaccine model in an NHS primary care setting
Commercial
Yes
Sublicensing
No
Datasets
4
Files released
28

Datasets: Emergency Care Data Set (ECDS); Hospital Episode Statistics Accident and Emergency (HES A and E); Hospital Episode Statistics Admitted Patient Care (HES APC); Hospital Episode Statistics Outpatients (HES OP)

Objective for processing

Background

Elevated low-density lipoprotein associated cholesterol (LDL-C), is one of the major risk factors for coronary heart disease (CHD). Despite advances in treatment, atherosclerotic cardiovascular disease (ASCVD) is the leading cause of death and disability worldwide. Despite the proven efficacy of statins, there is still a considerable variability in individuals to these drugs, even when being treated with a high intensity regime. Furthermore, not all people tolerate statins or are able to take statins at sufficient intensive doses. Therefore, there is a clear unmet medical need for additional options beyond current available oral treatments for the lowering of LDL-C.

Inclisiran is a medicine used to lower LDL-C. Raised LDL-C is generally accepted to be an independent risk factor for the development and progression of atherosclerotic cardiovascular disease. Novartis Pharmaceuticals UK Limited holds the UK marketing authorisation for Inclisiran and there is a collaboration agreement in place between Novartis and NHS England. In accordance with the collaboration agreement, it is aimed that 300,000 patients with raised LDL-C will be prescribed Inclisiran over three years so they may benefit from its LDL-C lowering effects. The SPIRIT study, sponsored and funded by Novartis, will inform the national roll out of Inclisiran within a UK primary care setting. While Novartis could benefit financially if Inclisiran is widely prescribed within the NHS, it is expected that this large number of patients will derive benefit in terms of LDL-C reduction.

Inclisiran is a treatment for elevated low-density lipoprotein associated cholesterol and can be given in primary care settings as a twice-yearly injection to people with high cholesterol who have already had a previous cardiovascular event to reduce the chances of them having another. It can be used on its own or alongside statins or other cholesterol lowering drugs. Inclisiran works in a new way. It is the first of a new type of cholesterol-lowering treatment which uses ribonucleic acid (RNA) interference (RNAi) to boost the liver’s ability to remove harmful cholesterol from the blood. Ribonucleic acid is a nucleic acid present in all living cells. RNAi refers to a phenomenon where small pieces of RNA can shut down protein translation by binding to and causing the destruction of messenger RNAs that code for those proteins.

The efficacy of inclisiran has already been evaluated in three phase III studies (ORION-9, -10, and -11; conducted between November 2017 and September 2019 by The Medicines Company, which was subsequently acquired by Novartis Pharmaceuticals) in patients with ASCVD or ASCVD risk equivalents (e.g. type 2 diabetes mellitus) and/or familial hypercholesterolaemia. These preliminary observations are consistent with the general concept that however LDL-C is lowered, it is thought to result in reduced risk of future cardiovascular events. The overall safety and tolerability profile was generally similar between the inclisiran and placebo groups.

However, it is acknowledged that randomised clinical trials, by definition, are highly controlled and enrol a more select patient population than is expected to be prescribed the medicine post-approval. The impact of a new treatment on patient healthcare seeking behaviour and utilisation of local healthcare services is hard to measure from clinical studies with their own schedule of defined visits and procedures, whereby the clinician and patient are following a prescriptive protocol rather than the usual clinical practice. This study seeks to study the effectiveness of inclisiran in a real-world setting, rather than just the efficacy as measured in the previous phase III studies.

Study Design

This is an implementation research study, the aim of which is to evaluate the practicality and acceptability of administering inclisiran subcutaneously (via injection) in GP practices (in a vaccine-like programme) to consenting participants who have elevated LDL-C and are on established lipid lowering medication or have been recommended lipid lowering therapy by their healthcare provider but are unable to tolerate treatment. 805 participants were randomised onto the trial between July 2021 and March 2022 within the Greater Manchester Area. Recruitment is complete. Participants are split evenly per treatment group into the 3 groups described below at up to 30 primary care centres will be recruited.

For clarity, implementation research is commonly defined as the study of methods and strategies to promote the uptake of interventions that have proven effective into routine practice, with the aim of improving population health; how to organise, deliver and maintain an innovative treatment for ASCVD in a primary care setting in a sustainable way. Implementation research seeks to understand and work within real world conditions and is especially concerned with the users of the research and not purely the production of knowledge. In the case of this study, the users are patients and healthcare providers who are, respectively, receiving and administering inclisiran (or managing the administration thereof) within GP practices.

The study is based on the following principles:

- It is run in the setting where inclisiran is intended to be implemented in clinical practice, with the intention of understanding the effects of innovations within the real-world conditions of everyday clinical practice

- Inclusion / exclusion criteria reflect the patient population for whom inclisiran is intended to be used, rather than selecting patients who are suitable for a standard clinical trial

- Health delivery context: taking account of institutional and health system contexts – including the viewpoints of various stakeholder including commissioners, system managers and clinicians

This study will be conducted using North West E Health’s (NWEH’s) ConneXon clinical trials platform which integrates patient level electronic healthcare record data from primary care, secondary care, and national data sources, to support the integration of ‘real-world evidence’ from individually consented participants. ConneXon has been validated for use in clinical studies.

Most of the study data will be extracted directly from the patient electronic medical record (EMR) in order to minimise direct participant contact and maximise the outcomes of interest related to implementation (patients consent to data from their GP and hospital records to be collected). Some study specific data not routinely collected will also be reported by the investigator or delegate in an integrated Electronic Case Report Form (e-CRF) for accuracy and in compliance with regulatory standards.

The study is divided into three elements:

1. A prospective phase IIIb intervention with 3 groups of patients:

a. Group 1: Participants will continue to receive their existing lipid lowering therapy plus behavioural support

b. Group 2: Participants will continue to receive their existing lipid lowering therapy, plus inclisiran injection

c. Group 3: Participants will continue to receive their existing lipid lowering therapy, plus inclisiran injection, plus behavioural support. (Behavioural support consists of a regular support telephone call to motivate patients to make effective choices for self-management including behavioural change, goal setting, and empowerment)

2. An observational data assessment utilising the EMR held in primary and secondary care, and analysing data collected within these records during normal clinical practice to examine ongoing healthcare resource utilisation (HRU) and outcomes in the patient cohort

3. A process evaluation that will ascertain the views of patients and healthcare providers about the service they have received or provided and its potential for wider use across the NHS

Objective for Processing

The primary objective of this study is to demonstrate superiority of inclisiran +/- behavioural support compared to the patient’s usual lipid lowering drugs + behavioural support in a primary care setting (i.e. the 3 groups of patients described in point 1 above), in reducing the percentage change in LDL-C from baseline to Day 270 in adults with elevated LDL-C.

The secondary objectives of this study are to evaluate user satisfaction/experience and process evaluation for the 3 groups of patients by means of:

- Validated questionnaires to measure patient satisfaction, patient activation and empowerment, and patient adherence to cardiovascular disease self-management

- A process evaluation conducted using the Consolidated Framework for Implementation Research (CFIR) which will explore inclisiran delivery at three levels

- Feasibility and acceptability of delivery models for inclisiran to patients

- Feasibility and acceptability of delivery models for inclisiran to providers

- Wider use of the proposed delivery models across the NHS (outer setting)

- The service costs of each delivery model

- The acceptability and perceived sustainability of patient identification and referral routes

- Serious adverse event profile

NB. Patient activation is a measure of a person's knowledge, skills, and confidence to manage their own health and wellbeing. Patient empowerment is a process through which people gain greater control over decisions and actions affecting their health.

The exploratory objectives of this study are to compare the 3 groups of patients on the following assessments:

- Total lipid profile (total cholesterol, HDL-C, triglycerides), blood pressure, weight, BMI from baseline to end of study visit.

- Healthcare resource utilisation during the period of the study taken from the primary and secondary care EMR e.g. number of outpatient visits, number of hospital admissions, number of A&E visits, number of primary care visits.

- Assessments of treatment simplicity, resources used for treatment, and treatment impact will be made from bespoke questionnaires based on standard questionnaires used in the assessment of diabetes treatments.

Secondary care data from HES is crucial for the complete analysis of the service costs of each model, Healthcare Resource Utilisation (HRU) analysis, and serious adverse event profile for all patients participating in the study.

Legal Bases

Processing of the data is justified under the following UK GDPR Articles:

9(2)(j)– Scientific research. Also, improvement in public health due to increased uptake of inclisiran is in the public interest

6(1)(f) – It is a legitimate interest of Novartis to investigate means of most effectively delivering a proven therapy. The outcome of a Legitimate Interest Assessment conducted by Novartis: The processing may be within the public interest, as it assists with achieving the clinical study aim of providing new and innovative medicines to patients and improving population health. All parties involved in the processing have an interest in this aim.

Novartis are a pharmaceutical company who have an interest in developing therapies for treating and preventing coronary heart disease. Novartis are interested in understanding how best to deliver their proven therapy for lowering LDL-C in a way that increases uptake and improves public health. Access to primary care data from GP EMR systems and secondary care data from HES data sets will allow for a full statistical analysis of HRU. This analysis will a) inform the evaluation of the superiority of inclisiran when delivered using the described model and, hence, support the primary objective of the study, and b) allow evaluation of the service costs of each delivery model and, hence, support this aspect of the secondary objectives of the study.

All participating patients have given informed consent and the study has been approved by an independent Research Ethics Committee. This study does not present any harm to the public.

Data Requested

Emergency Care DataSet (ECDS), Hospital Episode Statistics (HES) Outpatients, Admitted Patient Care, and A+E data is requested so that the patient’s journey across the whole secondary care setting can be analysed. This information, along with primary care data from GPs, will be used to compare the total primary and secondary healthcare resources used by the three patient cohorts and establish if inclisiran and/or behavioural support reduces HRU.

Record level data is required, but no identifiable or sensitive data are being requested. The data requested is minimised to only that of participating patients based on basic demographics (e.g. month and year of birth – to cross reference to primary care data), appointments/attendance/admissions/discharges/periods of care, treatment, diagnoses, and healthcare resource groups. A significant number of events for patients with ASCVD which occur in secondary care are not coded in primary care. These data are required for the calculation of HRU; without secondary care data the full HRU analysis could not be performed.

To address the UK GDPR principle of minimisation, only data for the period 5 years prior to the patient’s date of consent and throughout the course of the study (i.e. up to the end of December 2022) will be required. The first patient was recruited onto the study in July 2021, so HES data sets back to 2016/17 have been selected in this application to accommodate this (i.e. back to at least July 2016). Date of consent will be provided to NHS Digital, only 5-years of ‘pre-consent’ data for each patient can be delivered. This option is requested in the interest of further data minimisation.

Only pseudonymised data is being sought from NHS Digital, although NWEH supply NHS Digital with NHS number and date of birth to allow the correct patient cohort to be identified. No sensitive data is requested.

The population of 300 patients per arm of the study was chosen as this is the sample size necessary to detect statistically significant differences in outcomes between the three groups.

The geography of the study is already restricted to the Greater Manchester area. No further reduction in the data requested can be made based on geography.

Study participants are aged 18 years or older. To apply any further age restriction would undermine the real-world principles of the study.

Data from 5 years prior to enrolment on the study and up to the end of the study (end December 2022) is sought to allow a meaningful comparison of pre- and post-enrolment HRU. ECDS does not contain data for the full 5 years, so data from the HES A&E data set is being requested to provide this.

Only basic demographics (e.g. month and year of birth – to cross reference to primary care data), attendance, treatment, diagnoses, investigations, and conditions have been requested. The full range of these data are necessary for a complete HRU analysis.

The patients consented onto the study are from the Greater Manchester (GM) area and are registered with GPs in that area. Secondary care data is, therefore, likely to come from GM hospitals but could come from hospitals in other areas if, for example, patients had unscheduled visits while travelling or had to attend specialist clinics outside GM. Part of the rationale of using patient’s electronic records in a Real-World study such as this is to minimise interaction with patients and reduce any intrusion.

Organisations involved and their roles:

Novartis Pharmaceuticals UK Ltd

- Study Sponsor/funding body

- Data Controller

- Data Processor

NorthWest EHealth Limited (NWEH)*

- Data Processor

Northern Care Alliance NHS Foundation Trust (NCA)

- Data Processor

- Provide Azure cloud hosting service for NWEH

Microsoft Limited

- Data Processor

- Provide Azure cloud from NCA

Restore PLC

- Used for data storage / archiving

Wellbeing Ltd**

- Data Processor

NHS England (NHSE)

- There is an ongoing collaboration between Novartis and NHSE to improve lipid management in England. The funding for this study is coming from a budget agreed between Novartis and NHSE as part of the collaboration. For regulatory purposes Novartis is the study sponsor and responsible for setting the objectives and the conduct of the study. NHSE had no responsibility or accountability in the development of the study protocol and have had no involvement in the conduct of the study. However, as collaborators, NHSE will receive outputs of the study (e.g., publications, clinical study report and process evaluation reports).

*NWEH is wholly directed by Novartis on all aspects of data processing. The eCRF was developed by NWEH based on Novartis' study protocol. The data requested from NHS Digital and from GPs was that which will allow the objectives of the protocol to be fulfilled. NWEH will link data from the eCRF, HES, and GP systems and deliver it to Novartis in a format specified by Novartis for them to perform their own analysis.

**Wellbeing provides a 3rd party primary care data extraction service which extracts data from GP EMR systems and delivers it to NWEH. It does not process the GP data in any other way and will not process the data requested from NHS Digital in any way whatsoever.

Expected output

There are several planned reports and publications from this study. The planned activities are outlined below:

- Documents shared by Novartis with NHS England and Academic Health Science Networks (AHSNs) - textual reports with no patient details

- Patient report #1: report on number of patients meeting broad ‘at risk’ criteria who may be eligible for treatment with inclisiran in the study. Completed January 2022

- Process evaluation #1: early insights report based on feed-back from commissioners, patients, and healthcare professionals. Completed January 2022

- Patient report #2: report on number of patients who meet the full inclusion criteria (i.e. are eligible for inclisiran in the study). Completed June 2022

(Note: the above reports haven't used NHS Digital data, but they do feed into the research as they add background to the research).

- Process evaluation #2: in-depth report based on feed-back from commissioners, patients, and healthcare professionals. Estimated Q2 2023

- Full Clinical Study Report: inclisiran efficacy, patient reported outcomes, safety outcomes, patient demographics, process evaluation summary, and HRU (cost) analysis across the delivery methods

- Peer reviewed publications - aggregate data with small numbers suppressed

- Patient Identification and SNOMED codes / national case findings. Submission to Cardiovascular Research estimated May 2023

- Study Methodology publication. Submission to British Medical Journal Open estimated May 2023

- Patient engagement: Prior to commencement of the trial a patient focus group was set up by NWEH (on behalf of Novartis) to involve patients at the development stage of the process, to help improve and inform the study, as well as providing an opportunity to gain a better understanding of the patient’s needs. In addition, it offered a chance for the protocol to be tested, issues to be identified, and problems to be resolved before a study opened for recruitment. The study concluded overwhelmingly that participants had a positive opinion about the study. In fact, all those interviewed stated they would be interested in taking part in the study if they were offered the opportunity. When discussed with the researcher, the vaccine like model was perceived as a good alternative to their current medications. From questioning, no participants had any major concerns regarding the study design or the drug administration. Novartis will also be sending participants a summary of findings at the conclusion of the study to keep study participants up to date with the study outcomes.

- Data output: Northwest EHealth will produce a dataset of linked data from the eCRF, GP EMR systems, and the HES datasets. This data will be transformed into the standard format required for submission to regulatory authorities for analysis by Novartis. The data will be patient level and pseudonymised but Novartis will not have access to the pseudonymization key or identifiers and cannot re-identify the patients (see ‘Linked data’ under ‘Processing Activities’). This linked data is necessary for the subsequent production of the Full Clinical Report by Novartis (including HRU analysis) for dissemination to NHS England.

Benefits reported

Yielded Benefits is not a requirement for new applications.

Register history

When this agreement appeared in, or was edited in, each monthly edition of the register. Built by comparing every edition this site holds.

Cite this page

NHS England (2026) Data Uses Register, September 2026 edition, agreement DARS-NIC-421602-N3B0X, “VICTORION-Spirit: Phase IIIb, multicentre, randomised controlled study to evaluate the implementation of inclisiran sodium in participants with, or at risk of, Atherosclerotic Cardiovascular Disease and elevated Low Density Lipoprotein Cholesterol using a vaccine model in an NHS primary care setting”. Read via NHS Data Access Explorer (unofficial), https://healthdatauses.uk/agreements/dars-nic-421602-n3b0x/ (accessed [date]).

This address stays the same, but the page is rebuilt with each monthly edition, so the citation names the edition it shows. Every edition's data is kept in the facts store.

Source: datausesregister_september2026.xlsx, September 2026 edition of the NHS England Data Uses Register. Search that workbook for DARS-NIC-421602-N3B0X to see the original rows.