lly be adjusted moving forward. For clarity, we will use the different principles contained in the UK GDPR as a basis for review, which broadly align with the 6 ethics principles developed by Bristol. Lawfulness, Fairness and Transparency Bristol cites a range of legislative gateways to justify the use of the TFD, this is in line with precedents set before and after its development. Our conversations with the Data Protection Officer and Information Governance professionals in Bristol City Council indicate they were all confident of the lawful underpinning of the TFD and accepted the lawfulness of the approach taken. “We've had enough very qualified Information Governance professionals working on this to be able to provide a robust argument to any conflicts or anybody saying … we don't have a legal gateway.” (Head of Service) Social Finance Limited +44 (0) 20 7770 6836 87 Vauxhall Walk, London SE11 5HJ socialfinance.org.uk 66 However, using legislative gateways instead of consent for data sharing did represent a change. As noted by the Head of Service: “Our approach to the information governance was very, very new, probably the first in the country to do what we did around public task and relying on legislation pretty much no one had ever done that before.” (Head of Service) The issue of consent was raised with us on a number of occasions by practitioners, which suggests a wider lack of understanding around information governance in respect of the TFD at a practitioner level. Practitioners also reported that they struggle with feeling confident about speaking to other professionals when a family has not been asked for consent, in turn suggesting that more support is needed beyond communication of a change in policy. This lack of clarity among staff may, in part, explain 