Access and Disclosure Protocol
Protocol governing access to and disclosure of information to the Gosport Independent Panel and publication into the public domain
This protocol sets out the arrangements for disclosure of information held by organisations to the
Gosport Independent Panel (GIP). The protocol will apply to the provision of all relevant
information held by organisations from which the GIP requests disclosure.
Background and aims
1. This protocol is designed to ensure that:
Organisations holding relevant information (donating organisations), the families and the public know how the GIP is approaching provision of information, specifically that held by public sector organisations. Separate arrangements will be put in place for individuals who may also hold information which will be of interest to the Panel.
The GIP receives full disclosure of the information it requires according to a schedule and timeframe agreed with the organisations concerned.
There is clear understanding about how information made available to the Panel will be dealt with.
2. The Gosport Independent Panel has been set up to address concerns raised by families
over a number of years about the care of their relatives at Gosport War Memorial Hospital
and other associated locations, and about the subsequent investigations into the deaths of some
of them. The Panel will oversee the maximum possible public disclosure of all relevant
documentary information; it is tasked with obtaining exceptional and full disclosure of all
relevant documentation and presenting a final report to the Secretary of State for Health for
publication in Parliament.
The Panel’s principles include ‘the family first’ in terms of the release of the Panel’s findings and Report and maximum possible disclosure of documents and information by the Panel to the family. The full Terms of Reference of the Panel are attached at Appendix A below.
3. The GIP is procuring an e-Discovery platform called Relativity which is similar to the system that has been used very successfully to support the work of other independent panels. The Panel will use this system to store, collate, organise and research all material it receives from the providing organisations.
Provision of documents
4. In this protocol, ‘document’ means anything in which information of any description is recorded. The Independent Panel’s requirement for documents will be wide ranging. It may (depending on context) include copies of medical records, death certificates, statements, formal and informal notebooks, policy statements, audio recordings, video footage, information stored electronically on computer systems, meeting notes and minutes, manuscript notes, memoranda, correspondence (post and/or fax) and internal and external email communications.
Where organisations are thought to hold information that may be relevant to the work of the Panel they will be asked to institute a thorough search for such information. Search terms should be widely defined and organisations will be expected to demonstrate to the Panel the extent of their search for relevant information. They must also maintain accurate logs of searches completed in order to produce documents to be supplied to the Independent Panel, together with a comprehensive list of documents provided.
Where relevant information is found, arrangements will be made to catalogue that information in a way that is compatible with the Relativity system being used to collate and store all the information provided to the Panel.
5. Whether or not relevant information is found, the Chief Executive (or nominated representative) of all organisations thought by the Panel to be potential donating organisations will be required to sign a certificate, before the publication of the final Report of the Panel, to the effect that such a search was carried out and that either no information was found or that all information found was disclosed to the Panel. These stakeholder certificates are available on this website. Chapter 11 of the Panel’s final Report lists those organisations that did not respond to this requirement.
Disclosure of information to the GIP
6. In order to ensure that the work of the Panel is carried out as expeditiously as possible, a process of ‘parallel disclosure’ will be put in place, which will enable information held by donating organisations to be examined in accordance with the Terms of Reference separately from the discussions that may need to take place relating to disclosure of this same information into the public domain.
7. The Panel will require all documentation to be disclosed to the Panel in an unredacted
format in the first instance against the security of a confidentiality and non-disclosure
8. The Independent Panel will ensure that:
it, its advisers and staff follow the relevant government security guidance and procedures for the transmission, handling, storage and removal of documents
appropriate procedures as set out below are followed before documents are included in its Report and therefore prepared for publication
it files, records, stores and retains documents passed to it as well as any documents it generates in a manner consistent with government standards on filing, record keeping, storage and retention of official material.
An exemplar confidentiality and non-disclosure agreement is attached for information at Appendix B.
Onward disclosure of documents by the Independent Panel
9. It is expected that the Independent Panel will wish to draw on information contained in documents provided in accordance with this protocol when producing its final (and any provisional) Report. It may also wish to evidence that Report by referencing and publishing the source documentation on which it is based.
10. Providing organisations must review all information provided on an unredacted basis and inform the Panel of any concerns there are in relation to the publication of specific documents or parts of documents. For ease of reference, access to Relativity will be facilitated for all providing organisations once the material has been catalogued and loaded onto the system.
Most of the organisations providing information to the Panel will be subject to the Freedom of Information Act 2000. The views of the Panel in relation to its interpretation of the limited number of exemptions that might apply, were the information to be subject to an FOI request, is attached at Appendix C.
For the avoidance of doubt, any word, paragraph or document that an organisation has disclosed on an unredacted basis to the Panel, but which it wishes to protect from public disclosure, must be specifically identified by the organisation concerned as part of the second phase of ‘parallel disclosure’. Organisations must inform the Panel of the reasons for such concerns. Negotiations will then take place between Christine Gifford, who is leading for the Panel on all matters relating to access to and disclosure of information, and the organisations concerned. Every effort will be made to achieve disclosure by consent but, where agreement cannot be reached relating to disclosure into the public domain, the Panel will take the view that consent has been withheld unreasonably and, as with previous independent panels, the name of the organisation concerned and a description of the material that it wished to protect will be included in the final Report of the Panel.
11. It is recognised that organisations will also have concerns about compliance with the Data Protection Act 1998 and the Human Rights Act 1998. Following discussion with the Information Commissioner’s Office, the Panel has prepared a document that explains the provisions of the Data Protection Act 1998 in the context of its work, and a specific exemplar Data Processing Agreement, which it is felt will provide organisations with assurance relating to the processing of both ‘personal data’ and ‘sensitive personal data’. These documents are attached at Appendix D.
12. The electronic document management system that will be used by the Panel will follow an accreditation process, ensuring it is secure to hold documents with a protective marking up to, and including, Restricted/Official Sensitive. It is the view of the Panel that there will be very little material held by providing organisations that will attract a higher level of protective marking. However, should this exceptionally be the case, and on review it is not possible to downgrade the information to Restricted/Official Sensitive, the providing organisation should discuss this issue with Christine Gifford.
13. Members of the Secretariat supporting the work of the Panel will liaise with donating
organisations on an individual basis to ensure that any assistance that organisations
require is made available. It is essential that, once a timeframe is agreed with a donating
organisation, that timeframe is adhered to.
14. Donating organisations must ensure that they retain original versions of all documents relevant to the Independent Panel’s work and that any information supplied to the Panel is not destroyed before the Panel has completed its work; where appropriate advice should be sought from the Panel Secretariat.
Public disclosure process
15. The Terms of Reference of the GIP include the ‘family first’ principle in terms of the release of its findings and Report. Accordingly, the Independent Panel will ensure that, prior to publication the families of those concerned are provided with access on a confidential basis to its completed Report and any associated documentation prior to its publication in accordance with arrangements made by the Secretary of State in Parliament.
Gosport Independent Panel – Terms of Reference
1.1 Concerns about the care of older patients in Gosport War Memorial Hospital have been the subject of scrutiny since 1998. Families of those who died have persistently sought a full and independent investigation into the circumstances surrounding the death of their relatives and into the care they received prior to death.
1.2 There have been numerous investigations into the events surrounding these deaths: three police investigations, a Commission for Health Improvement investigation; a General Medical Council (GMC) inquiry; the Council for Healthcare Regulatory Excellence review and inquests into eleven deaths at the hospital. In 2010, after reviewing the material from the ten inquests and the GMC proceedings, the Crown Prosecution Service (CPS) concluded that ‘the evidence is insufficient to provide a realistic prospect of conviction for an offence of gross negligence manslaughter .... in respect of each of the ten deaths reviewed.’
1.3 In 2013, the Department of Health published a clinical audit of care which had taken place in 2003 by Professor Richard Baker covering the period 1988-2000. The report concluded that ‘a practice of almost routine use of opiates before death had been followed in the care of patients of the Department of Medicine for Elderly People at Gosport hospital .... The practice almost certainly had shortened the lives of some patients, and it cannot be ruled out that a small number of these would otherwise have been eventually discharged from hospital alive’.
1.4 For the families, there remain unanswered questions about the care of their relatives, the circumstances surrounding their treatment and death and the slow progress of the various investigations.
1.5 In light of this, Norman Lamb, the-then Minister of State for Care and Support at DH established the Gosport Independent Panel, under the chairmanship of Bishop James Jones, to review the documentary evidence held across a range of organisations concerning the initial care of families’ relatives and the subsequent investigations into their deaths in Gosport War Memorial Hospital.
Terms of reference
1.6 The Government is committed to maximum possible public disclosure of the documentation relating to the events at Gosport War Memorial Hospital from all possible sources.
1.7 The remit of the independent panel is to:
- Consult with the families of the deceased and of those treated to ensure that the views of
those affected are taken into consideration;
- Obtain, examine and analyse documentation from all relevant organisations and individuals
(governmental and non-governmental) to include:
Undertaking the review of historic health and social care records to establish treatment prior to death and the care of the elderly and vulnerable in the hospital;
Examining the role of Gosport War Memorial Hospital and Redclyffe Annexe management, both clinical and administrative, and staff and other health and social care organisations. This will include their response to any concerns which were raised with them;
Reviewing all investigations related to complaints made to and concerns raised with all other relevant organisations and individuals;
Reviewing the relationships between the different investigations and their relationship with the families.
1.8 The Gosport Independent Panel will:
- Oversee the maximum possible public disclosure of all relevant information relating to
unexpected deaths and treatment at the Gosport War Memorial Hospital;
- Manage the process of public disclosure, initially to the affected families;
- Produce a report which will provide an overview of the information reviewed by the panel
and will illustrate how the information disclosed adds to public understanding of these
events and their aftermath.
- Establish an on-line archive of Gosport documentation, including a catalogue of all relevant
information and a commentary on any information withheld for the benefit of the families or
on legal or other grounds.
1.9 The review by the Independent Panel is expected to complete by spring 2018. The Secretary of State for Health will make arrangements for publication of the final report to Parliament.
Confidentiality and Non-Disclosure Agreement
This agreement forms part of the Access and Disclosure Protocol which governs the working relationship between the Panel and any organisation or individual who may provide it with relevant information. The terms of this agreement are to be read in accordance with the Terms of Reference of the Gosport Independent Panel (Appendix A) and the documents relating to the Data Protection Act 1998 and the Data Processing Agreement (Appendix D) all of which are attached to the Protocol.
The terms of reference of the Gosport Independent Panel provide that the fundamental principle underpinning the Panel’s work will be that of full disclosure of documentation and no redaction of content.
The Access and Disclosure Protocol makes it clear that it is the expectation of the Panel that initially all relevant information held by donating organisations and/or individuals will be disclosed to the Panel unredacted. Subsequently those who have provided such information to the Panel will be asked to identify any information that they feel should be protected from disclosure into the public domain should that prove necessary in support of the findings of the Panel.
By virtue of this agreement an undertaking is given that where information is disclosed to panel members and/or those working on their behalf under an explicit condition of confidentiality which is not waived by the donating organisation, panel members and/or those working on their behalf will maintain the confidentiality of that information.
Acting as authorised by the Gosport Independent Panel, I hereby give an undertaking that I will abide by the terms of this agreement.
Name: ........................................................................................ Role: ..........................................................................................
Signed: ....................................................................................... Date: ...........................................................................................
Panel views on the interpretation of exemptions to disclosure which might be thought to be engaged under the Data Protection Act 1998 and the Freedom of Information Act 2000
1.1 Much of the information relevant to the work of the Gosport Independent Panel will be
subject to the Data Protection Act 1998 (DPA) and the Freedom of Information Act 2000 (FOIA). The Panel is of the view that, when considering whether to disclose information into
the public domain (having already disclosed information to the Panel as part of the initial
parallel process of supplying unredacted information), donating organisations might find it
useful to be aware of the views of the Panel in relation to the engagement of exemptions
under the FOIA, were requests to be made.
2. The Data Protection Act 1998
2.1 It is the expectation of the Panel that the identities of Ministers, senior healthcare professionals, those known to patients and/or their families by their name, and the identities of other senior officials holding an accountable role in an organisation at a time of interest to the Panel will not be redacted prior to publication of the Report of the Panel.
2.2 Where information identifying individuals is not already in the public domain, organisations
may decide to redact personal data and sensitive personal data relating to:
- civil servants who were not Grade 7s (or Principal Officers) at the time the document in question was produced
- police officers who were constables or other ranks up to and including sergeant at the time the document was produced
- other junior public employees who were not in a position to determine their agency’s response to events which are of interest to the Panel.
2.3 However, it is important to note that if the Panel can evidence that such information is already in the public domain (in its widest sense) then the expectation will be that the information will not be redacted.
2.4 Where redaction of identities is required, this will normally be accomplished by the redaction
of names, addresses and other personal data such as signatures. In some instances, it may
also be necessary to redact other information (for instance a job title and name and address
of employer) where this could reasonably be used to identify an individual. However, this
should not lead to blanket and widespread redaction. As the Information Commissioner has
made clear, the existence of a very slight hypothetical possibility that someone might be able
to reconstruct data in such a way that the data subject is identified is not sufficient to require
redaction of that data.
3. Freedom of Information Act 2000
Legal and professional privilege
3.1 Information holders may consider some records to be potentially covered by legal and professional privilege (LPP), though given the passage of time and events this will have been eroded in many cases. In line with the principle of maximum possible disclosure, the Panel’s expectation is that information holders will waive LPP where the issue arises. The Panel will consider on a case-by-case basis any exceptional circumstances where information holders believe this not to be possible.
Freedom of Information Act 2000
Information provided in confidence
For information provided in confidence, information holders should refer to the requirements of section 41 of the Freedom of Information Act, which sets strict criteria which must be met if information is to be withheld from release.
The Act requires that for information to be exempt from release:
It must have a quality of confidence and can only have been shared even within an organisation on a very limited basis.
This exemption can only apply where there is an external third-party relationship relevant to the issue of confidence.
Information can only be exempt from release in instances where disclosure would represent a breach of confidence that would be legally actionable (and even here, the Panel would wish to take a view as to the likely risk of this occurring).
The Panel’s view is that the legal defence to any breach of confidence based on disclosure in the public interest is of over-riding importance in the context of its work. Given this and the length of time since confidence was originally claimed, it expects very little if any of the information in existence to be considered to be confidential in the current climate.
DATA PROTECTION ACT 1998
1.1 The Gosport Independent Panel has registered with the Information Commissioner as a Data Controller in respect of all personal data held by the Panel. As such, the Panel will process such data in accordance with the Data Protection Act 1998 (DPA) and, in particular, in accordance with the Data Protection Principles set out in Schedule 1 to the Act.
1.2 Many of the organisations providing information to the Panel will find that some of that information is defined as either ‘personal data’ or ‘sensitive personal data’ under the DPA.
1.3 This paper sets out how the Panel will manage that data and comply with the Principles and, therefore, the Act.
2. Principle 1
Personal data shall be processed fairly and lawfully and, in particular, shall not be processed unless –
a. At least one of the conditions set out in Schedule 2 is met, and
b. In the case of sensitive personal data, at least one of the conditions in Schedule 3 is met.
2.1 The Panel’s powers to act derive solely from its Terms of Reference as set out by the Minister of State for the Department of Health. Provided that the Panel processes personal data only to the extent that it is necessary to do so to comply with its Terms of Reference, then it will meet the conditions set out in Principle 1 since paragraph 5 (c) of Schedule 2 to the Act specifies that processing in the exercise of the functions of the Crown, a Minister of the Crown, or a government department is permissible and the Panel is exercising the functions of the Minister in this regard.
2.2 The provision at paragraph 7 (c) of Schedule 3 permits the Panel to process sensitive personal data in the furtherance of its Terms of Reference and again such processing will be limited to compliance with the conditions for processing set out in the Act.
2.3 The Panel will, more generally, ensure that its processing of personal data is fair and lawful by its compliance with the other Data Protection Principles, as set out in this paper.
3. Principle 2
Personal data shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.
3.1 Principle 2 is closely linked to the conditions in the schedules relating to processing as established by the DPA. The Panel will only require organisations to provide personal data where that data might be considered to be relevant to the Panel’s Terms of Reference and will only process it in accordance with the provisions of the DPA.
3.2 The Panel may also obtain, or create, personal data, in relation to its functions as an employer or contractor of services. The Panel will process such data only insofar as it is necessary to do so to fulfil those functions.
4. Principle 3
Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
4.1 Organisations providing information will need to take a wide view of the extent to which personal data held by them will be relevant to the work of the Panel. Detailed analysis of the data will allow it to securely dispose of any personal data that proves not to be relevant, and organisations will be informed that this has been done so that they may in turn take appropriate action in relation to personal data that is no longer required or inaccurate. The process of parallel disclosure will ensure that only personal data with relevance to its findings will be published by the Panel and then only within the parameters established by the DPA.
5. Principle 4
Personal data shall be accurate and, where necessary, kept up to date.
5.1 The Panel is investigating historical data and part of its task is to consider the data as it was
at the particular time the data was created or used. However, with this proviso, it is essential
for the Panel’s work to be credible and to have the confidence of the public that any personal
data considered by the Panel in reaching its findings is accurate and remains so for the
duration of the Panel’s work. The Panel will require organisations to check personal data
that it is intended to publish just prior to publication to ensure continued accuracy.
5.2 The Panel will also follow such guidance as is available to it from its sponsor department, the Department of Health, to ensure that personal data held by the Panel for administrative, personnel or financial reasons are updated appropriately.
6. Principle 5
Personal data processed for any purpose, or purposes, shall not be kept for longer than is necessary for that purpose, or those purposes.
6.1 As noted above, if and when personal data is determined to be not relevant to the Panel’s remit, or not to be included in the final Report of the Panel, it will be destroyed and the originating department so informed.
7. Principle 6
Personal data shall be processed in accordance with the rights of data subjects under the Act.
7.1 Data subjects will be able to exercise their rights under the Act by writing to the Panel or emailing the Panel. Further details are available here.
7.2 Personal data held by the Panel may have been obtained from a number of different
providing organisations. If the Panel receives a Subject Access Request that relates to information originally provided by only one providing organisation, the request will be sent to
that organisation for response. However, where the Panel receives a Subject Access request
relating to information that has come from a number of organisations, the request will be
dealt with, in its entirety, by the Panel who will consult as necessary with the organisations
7.3 Where a subject access request is referred back to a single department, the Panel will not
abrogate its legal responsibility and will monitor the response of the department to the
7.4 Other subject rights, such as requests to cease processing personal data on grounds of damage or distress under section 10 of the DPA, may be sought by application and may be sent to the same address as that provided for Subject Access Requests.
8. Principle 7
Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
8.1 All the Panel’s IT has been sourced through government contracts, includes security measures appropriate to the sensitivity of the information held on it and has been / will be subject to appropriate accreditation processes.
8.2 Within the Panel’s offices, there are secure locks to prevent unauthorised access, and policies and procedures are in place to protect information overnight.
8.3 Working outside the office is limited to the use of an e-Discovery system, which has appropriate access controls in place.
9. Principle 8
Personal data shall not be transferred to a country or territory outside the European Economy Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
9.1 All the Panel’s IT arrangements, and those of its contractors, are based in the UK. The Panel has no plans to transfer personal data outside the UK.
9.2 The Panel’s Report will, in due course, be made publicly available. There can, therefore, be
no effective restriction on the Report being transferred outside the EEA. However, there is
every intention to be totally compliant with the DPA and exercise effective detailed oversight
over the fair and lawful processing of all personal data and sensitive personal data of interest
to the Panel.
DATA PROCESSING AGREEMENT
This agreement sets out the terms and conditions on which documents may be provided to the Independent Panel, its servants and agents for processing by them. It forms part of the Access and Disclosure Protocol established by the Gosport Independent Panel and should be read in conjunction with it.
1. The Parties
This agreement is between:
1.2 ............................................................ (Name of organisation or individual)
2.1 The objective of this agreement is to facilitate full unredacted disclosure of documentation held in relation the work which is to be undertaken by the Gosport Independent Panel in accordance with the Ministerial statement made by the Minister of State for Health on 8 December 2014. In that context this agreement outlines the data processing protocol for provision of documents by donating organisations to the Gosport Independent Panel, the digitisation of such documents and their management by Wordwave International Ltd on behalf of the Panel.
3.1 ‘Personal data’, ‘data controller’ and ‘subject access’ shall have the same meaning as set out in the Data Protection Act 1998.
3.2 All members of the Panel, its staff and advisers, and those at Wordwave International Ltd who are involved in assisting the Panel’s work are required to sign a confidentiality and non-disclosure agreement, which is attached as Appendix B.
4. Use and disclosure of data
4.1 The Panel has registered with the Information Commissioner as a Data Controller as defined by the Data Protection Act 1998.
4.2 Data disclosed to the Panel will be provided to Wordwave International Ltd on behalf of the Panel and Wordwave International Ltd will be a data processor. Wordwave International Ltd has signed an overarching confidentiality agreement which will apply to all the information processed by it in relation to its work with the Panel.
4.3 The Panel shall receive the data as a data processor but will then assume responsibility for directing its collation, organisation and analysis and shall therefore also be data controller of the personal data accessed under this agreement.
5. Requests for information
5.1 All processing of the data shall be conducted in accordance with the provisions of the Data
Protection Act 1998 and the Human Rights Act 1998.
5.2 If the Panel and/or Wordwave International Ltd receive a subject access request relating to data covered by this agreement where the data is held by a single organisation, the request will be forwarded to that organisation at the earliest opportunity. However the Panel will not abrogate its responsibilities in relation to compliance with the Data Protection Act 1998 and will monitor the response of the organisation concerned.
5.3 Where the Panel receives a subject access request which appears to relate to information which may have been provided by a number of organisations it will assume responsibility for dealing with the request consulting with the organisations concerned as required.
5.4 The Panel will itself respond to all requests relating to its own work and processes and/or any data it has changed.
5.5 If the Panel and/or Wordwave International Ltd receive any freedom of information requests relating to information covered by this agreement, such a request shall be forwarded to the FOI Unit of the Department of Health as soon as reasonably possible. The Department of Health has statutory responsibility for responding to any such requests made to the Panel and shall comply fully with the provisions of the Freedom of Information Act 2000 in doing so. The Panel will remind the Department of Health of its obligation under the Secretary of State’s Code of Practice on the discharge of public authorities functions issued under section 45 of the Freedom of Information Act to consult donating organisations before it responds to any such request. It will also request that the Department of Health keeps both the Panel and the donating organisation updated in relation to its response to any such request. If the Panel and/or Wordwave International Ltd receive any freedom of information request which relates solely to its own work and processes, the Panel will forward this to the Department of Health to respond without reference to donating organisations.
5.6 Data supplied to the Panel and Secretariat under this agreement will be used solely for the purpose of the review. Data will be stored on the Relativity system operated and managed by Wordwave International Ltd and processed in accordance with this agreement and the Access and Disclosure Protocol.
6.1 All employees of the Panel and Wordwave International Ltd directly involved in the management of personal data must be fully conversant with the terms of this agreement and the Access and Disclosure Protocol as well as providing the confidentiality and non-disclosure undertaking.
6.2 The Panel and Wordwave International Ltd will apply appropriate security measures, commensurate with the requirements of principle 7 of the Data Protection Act 1998 to all data provided.
6.3 Any security incidents, breaches and newly identified vulnerabilities must be reported to the Secretary to the Gosport Independent Panel at the earliest opportunity.
6.4 The Panel and Secretariat will ensure that the personal data provided is not used other than as identified within this agreement, the Confidentiality and Non-Disclosure Agreement and the Access and Disclosure Protocol, and that these agreements are complied with.
7. Data Protection and Human Rights
7.1 The use and disclosure of any personal data shall be in accordance with the obligations imposed upon the parties to this agreement by the Data Protection Act 1998 and the Human Rights Act 1998. All relevant codes of practice or data protection operating rules adopted by the parties will also reflect the data protection practices of each of the parties to this agreement.
8.1 At the conclusion of its work, the Panel will publish a Report, setting out its findings. It may
also choose to publish documents or parts of documents supplied to it under this agreement
which evidence its conclusions. It will only do so in compliance with its obligations as data
controller and in accordance with this agreement, the Confidentiality and Non-Disclosure Agreement all of which are part of the overarching Access and Disclosure Protocol
established by the Panel.
8.2 All data provided under this agreement shall be confidential and the terms of the confidentiality undertaking shall apply to all members of the Panel and Wordwave International Ltd, their employees and agents who will be involved in its processing.
8.3 For the avoidance of doubt, the obligations and the confidentiality imposed on the parties by
this agreement shall continue in full force and effect after the conclusion of the work of the
Donating Organisation: ......................................................
Gosport Independent Panel