Is Your TRE Actually a TRE? The ONS Five Safes Scorecard

15 questions. One honest answer each. Your vendor either passes the ONS Five Safes framework — or it doesn’t call itself a Trusted Research Environment.

In 2026, more platforms call themselves a “TRE” than actually qualify. The UK Statistics Authority Five Safes framework — the governing definition of a Trusted Research Environment, reaffirmed by the 2022 Goldacre Review — defines a TRE by five architectural pillars, not by marketing.

Score your platform against all five below. If it fails even one pillar, the name on the tin is wrong.

How to score

Read each question. Answer yes or no honestly. Count the “no” answers at the end. The number tells you whether you have a Trusted Research Environment, a secure analysis platform with TRE marketing, or a compliance liability.

No email required. No form. No gate. Score your vendor, score ours, score anyone’s.

Pillar 1 — Safe People

Are the humans who touch the data actually vetted, trained, and accountable?

1. Are researchers accessing the platform individually vetted — not just their institution?
2. Is researcher training renewed annually and enforced, not a one-time onboarding checkbox?
3. Are inactive researcher accounts auto-revoked after defined periods of non-use?

Pillar 2 — Safe Projects

Is every analysis authorized by governance — not by default platform access?

4. Does every analysis require explicit ethics + governance approval tied to a specific research question?
5. Are project approvals time-limited and renewable, not perpetual?
6. Can the data controller revoke an approved researcher’s project access independently of the vendor?

Pillar 3 — Safe Settings

Who actually controls the environment the data sits in?

7. Is the compute environment controlled by the data controller, or by the vendor?
8. Does the vendor have administrative access to your data at rest?
9. Can the data controller audit every system action end-to-end — without dependency on vendor-supplied logs?

Pillar 4 — Safe Data

Does the data stay where its governance already works?

10. Does your data remain at source, on infrastructure your governance team already trusts — or is a copy moved to the vendor’s cloud?
11. Is data pseudonymized and minimized before any analysis touches it?
12. If your contract with the vendor ended tomorrow, would any copy of your data remain in their systems, under their jurisdiction?

Pillar 5 — Safe Outputs

What actually leaves the environment — and who checks it?

13. Is every output — charts, models, summary statistics, derived datasets, trained AI — reviewed before it leaves the environment?
14. Is output review automated and consistent, or manual, ad-hoc, and dependent on researcher self-reporting?
15. Can an approved researcher download raw or derived data to a local machine? (Answer “yes” is a fail.)

Your score

• 0 “no” answers — you have a real TRE. The ONS Five Safes framework is satisfied. Rare in 2026.
• 1–3 “no” answers — you have a secure analysis platform, not a Trusted Research Environment. The distinction matters for regulatory submissions, patient-trust claims, and cross-border data agreements.
• 4+ “no” answers — your environment fails the Five Safes framework. This is a regulatory, reputational, and patient-trust exposure. A 2026 data incident on any platform scoring here is the kind of story that ends careers and contracts.

The architectural gap most platforms fail on

Most SaaS platforms marketing themselves as TREs pass Pillars 1 and 2 (Safe People, Safe Projects) because vetting and approval are procedural — you either do them or you don’t. They fail Pillars 3, 4, and 5 because those are architectural. You can’t bolt them on after the fact.

Specifically, a platform that copies your data into its own cloud fails Pillar 4 by definition. A platform that allows approved researchers to download raw or derived outputs fails Pillar 5 by definition. A platform where the vendor — not the data controller — owns the environment fails Pillar 3 by definition.

This is why the label on the tin matters. A secure analysis platform is a legitimate and useful product category. It is not a Trusted Research Environment.

Why Lifebit built federated from day one

Lifebit’s federated Trusted Research Environment was designed around the Five Safes from the architecture up:

• Safe Data — the data never leaves its source. The compute goes to the data. No copy is ever created in our cloud.
• Safe Settings — the data controller retains full sovereignty over the environment. Lifebit operates the platform; the data controller owns the data, the logs, and the audit trail.
• Safe Outputs — every output passes through an automated Airlock review before it leaves. No researcher can download raw or derived data to a local machine under any condition.

This is the architecture that powers Genomics England at national scale, the NIH, Singapore’s Ministry of Health, and Flatiron Health. It is the architecture every TRE buyer is going to be graded on for the next five years.

What to do next

If you scored your current vendor above a 0, you have three options:

1. Ask your vendor for their written answers to each of the 15 questions above. A real TRE vendor answers without hedging.
2. Read the full breakdown of federated vs SaaS TRE architectures against the Five Safes framework, and our explainer on what the UK Biobank incident reveals about SaaS TREs.
3. Book a 30-minute Five Safes assessment with Lifebit. We’ll walk your current architecture through the framework and tell you the gaps — whether you end up working with us or not.

This scorecard is a Lifebit-authored interpretation of the UK Statistics Authority Five Safes framework as applied to 2026 TRE vendor evaluation. We publish it free because owning the framework is the point — no email required, no form, no gate. Copy it. Share it. Use it to grade us.