Clearance to publish hospital data is separate permission from your institution — usually clinical governance, the medical director's office or a research office — to publish figures, outcomes or the hospital's name. Ethics approval covers whether the study may be done. Patient consent covers the individual. Institutional clearance covers the organisation's data and its name.
The three come from different offices, on different grounds, and holding one does not give you the others. The third can surface late: after acceptance, when a supervisor or a governance lead asks who authorised the release of those numbers.
What clearance to publish hospital data is
Institutional publication clearance is written permission from the organisation that holds the records for you to publish data drawn from them, to name the organisation, or both. It is an administrative and legal decision, not a scientific judgement and not an ethical review of your study.
The requirement exists because the hospital, not you, is normally the legal custodian of the clinical record, and publication moves institutional information into the public domain. Whether your own hospital requires clearance in writing is a local question with no international rule to look up. Three documents give the answer:
- Your contract of employment or honorary contract — its clauses on publication, intellectual property and public statements.
- The institution's research, publications or media policy, usually held by the research office.
- The data-sharing agreement under which you were given the dataset, if it came from a registry or an information team.
Ethics approval, patient consent and institutional clearance compared
These three permissions answer three different questions. Keep this table beside you while planning the study.
| Question | Ethics approval | Patient consent for publication | Institutional publication clearance |
|---|---|---|---|
| What it authorises | Doing the study and using records for research | Publishing details or images of one identifiable person | Releasing the organisation's data and using its name |
| Who grants it | A research ethics committee or review board | The patient or a legal representative | Clinical governance, the medical director, the research office or legal |
| When to obtain it | Before data collection | Before submission | Before submission, ideally at protocol stage |
| Evidence the journal sees | Committee, reference and date in the methods | A signed consent statement, held by you | Nothing; we do not ask for it at submission |
| If it is missing | The work cannot proceed, and may be retracted | Publishing identifiable material is a serious breach | A contractual matter, and possible forced withdrawal |
None of the three substitutes for another. An ethics committee approves research; it does not speak for the hospital board or its communications policy, and it cannot license you to attach the institution's name to a mortality figure.
Who grants institutional clearance, and where to send the request
The office that grants clearance to publish hospital data varies with the structure of the organisation. Send the request to one office and ask it to redirect you.
- Clinical governance, or quality and safety. Owns audit, incident and outcome data — the route for complication rates, mortality, readmissions or length of stay.
- The medical director's office. Signs off where the institution is named alongside clinical performance, or where findings could attract press interest.
- The research office. Handles study approvals and sponsorship, and often holds the publications policy itself.
- Information governance, or the data protection officer. Rules on whether the dataset may leave the organisation, and at what level of aggregation.
- Communications, and legal. Communications cares about naming, timing and embargo; legal becomes involved where a device, a supplier or a commercial agreement appears.
What in your manuscript triggers the requirement
Clearance becomes relevant when the manuscript contains any of this:
- The hospital or unit named anywhere other than the author affiliation — in the title, the methods or a figure caption.
- Unit-level outcome figures: mortality, complication or infection rates, revision rates, waiting times, readmissions.
- Data collected for audit, service evaluation or quality improvement rather than under a research protocol.
- Numbers that let the institution be ranked, compared with a named competitor, or identified from case volume and dates.
- Adverse events, near misses, complaints or incident data.
- Photographs of the estate, equipment or staff, and screenshots of the record system.
- Data supplied by a third party under agreement — a registry, a manufacturer, a laboratory.
Ask before you write the results, not after acceptance
Requesting clearance early changes what you write. Requesting it late changes only whether you may publish what you have written. Reporting outcomes at aggregate level is a design choice at protocol stage; after acceptance it means rewriting results, redrawing figures and asking the journal to hold production. Proof corrections exist for errors, not for restructuring a results section, and if clearance is refused after publication the remedies are correction or retraction — a permanent mark on an article that did nothing scientifically wrong.
A request template for clinical governance or the medical director's office
Send the template below as an email with the manuscript attached, written to be answered in one reply.
Subject: Request for institutional clearance to publish — [study short title]
Dear [Clinical Governance Lead / Medical Director's Office],
I am writing to request institutional clearance to publish a manuscript using data from [department or unit], [hospital name]. I am asking permission to publish the data below, and to name the institution in the published article.
Study title: [full title]
Study type: [chart review / case series / service evaluation / cohort]
Period covered: [dates]
Data source: [record system, theatre log, audit database, registry]
Number of records: [n]
Level of reporting: [aggregate figures / de-identified patient-level data / single case]
Ethics approval: [committee, reference, date — or: classified as service evaluation]
Patient consent: [signed consent for publication held on file / not applicable]
Identifiable content: [none / clinical photographs, consent obtained]
Institution named: [affiliation only / affiliation and methods]
Intended journal: [name]
Co-authors and affiliations: [list]
Attached: [manuscript, ethics documentation, consent form]Please could you confirm: whether clearance is granted; whether any figures must be aggregated, withheld or presented differently; whether the institution may be named as described; and whether information governance, communications or legal should see this first.
The manuscript will not be submitted until I have your written response. If this request should be handled elsewhere, please tell me where to send it. I would be grateful for a reply by [date].
[Name], [role], [department]
[Staff or honorary contract number]
[Email, telephone]
Keep the reply. A one-line email confirming approval as submitted is the document you need if the question is raised two years later.
If clearance is refused, delayed or granted with conditions
A refusal need not end the paper. Work through these in order:
- Ask for the reason in writing. A refusal on data protection grounds, one on reputational grounds, and one because the wrong office was asked have different remedies.
- Offer a lower level of reporting. Aggregating figures, widening date ranges or dropping a comparator can settle an information governance objection without damaging the paper.
- Offer to de-identify the institution. A paper can be written as work from a tertiary referral centre without loss of meaning. Check that case volume, dates and geography do not identify it anyway.
- Escalate by the named route. A publications policy normally names a review or appeal route. Use it, rather than approaching a second office in parallel.
- Recognise a suppression attempt. The ICMJE Recommendations hold that authors should avoid agreements with study sponsors that interfere with their access to all of the study's data, or with their ability to analyse and interpret it and to publish independently, and COPE publishes guidance on how research institutions and journals should cooperate when integrity concerns arise. Burying an unfavourable outcome because it embarrasses the organisation is an integrity problem, not a governance decision.
What you should not do is submit anyway and hope. A journal cannot grant a permission your employer has withheld.
What Directive Publications asks, and what our policy does not yet say
Our published pages require ethics approval and participant consent. They do not state a separate requirement for institutional publication clearance, and we are not going to pretend otherwise. Our editorial process does not ask whether your hospital has cleared the release of its data. That check is yours.
Two things follow. Nobody at the journal will find a missing clearance for you, so the gap surfaces only when a co-author or an employer raises it. And because submission is free and an APC falls due only on acceptance after peer review, a late failure costs you time rather than a fee. Two of those three permissions rest on the WMA Declaration of Helsinki, which holds that the goal of generating new knowledge can never take precedence over the rights and interests of individual participants. The third rests on your contract and your institution's own policy.
Before writing up your hospital's data, read our publication ethics policy, author guidelines and editorial policies, then Ethics Approval and Informed Consent: What Authors Must Report, How to Write and Publish a Case Report for single-patient data, and The Corresponding Author's Responsibilities for who must hold these permissions on file.