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Developed by:
U-MIC
1
CERTIFICATES OF
CONFIDENTIALITY
in human subjects research
Developed by:
U-MIC
University of Michigan IRB Collaborative
National Institutes of Health (NIH)
http://grants.nih.gov/grants/policy/coc/
Certificates of
Confidentiality
protect study data against
forced disclosure
• court orders
• subpoenas
Developed by:
U-MIC
federal
state
local
3
Certificates of
Confidentiality
adverse consequences
sensitive information
identifying characteristics
Developed by:
U-MIC
•
•
•
•
finances
employment
insurance coverage
reputation
4
sensitive information
examples
genetics
psychological health
sexuality
drug use
illegal behavior
Developed by:
U-MIC
5
identifying characteristics
examples
name
address
Social Security number
fingerprints
voiceprints
images
genetics and tissue
Developed by:
U-MIC
6
Certificates of
Confidentiality
Investigators should
• obtain IRB approval first
• include Certificate of Confidentiality language in their
consent documents
• tell IRB that they plan to apply to NIH for a Certificate of
Confidentiality
Developed by:
U-MIC
7
Certificates of
Confidentiality
protect sensitive information
collected prior to obtaining Certificate
maintained while Certificate is in effect
as long as investigator maintains data
Developed by:
U-MIC
8
Certificates of
Confidentiality
Certificate does not
•
•
•
•
automatically reduce all study risks
replace investigator’s responsibility to maintain confidentiality
protect against all forms of disclosure
protect against voluntary disclosure
Developed by:
U-MIC
9
Certificates of
Confidentiality
Certificate does not
•
•
•
•
automatically reduce all study risks
replace investigator’s responsibility to maintain confidentiality
protect against all forms of disclosure
protect against voluntary disclosure
Developed by:
U-MIC
10
Certificates of
Confidentiality
Certificate does not
•
•
•
•
automatically reduce all study risks
replace investigator’s responsibility to maintain confidentiality
protect against all forms of disclosure
protect against voluntary disclosure
Developed by:
U-MIC
11
Certificates of
Confidentiality
Certificate does not
•
•
•
•
automatically reduce all study risks
replace investigator’s responsibility to maintain confidentiality
protect against all forms of disclosure
protect against voluntary disclosure
Developed by:
U-MIC
12
Certificates of
Confidentiality
Certificate does not
•
•
•
•
automatically reduce all study risks
replace investigator’s responsibility to maintain confidentiality
protect against all forms of disclosure
protect against voluntary disclosure
Developed by:
U-MIC
13
Certificates of
Confidentiality
protect sensitive, identifiable information against
forced disclosure
• court orders
• subpoenas
Developed by:
U-MIC
14
National Institutes of Health (NIH)
http://grants.nih.gov/grants/policy/coc/
Certificates of
Confidentiality
Developed by:
U-MIC
15
THANK YOU.
Brian Seabolt
IRBMED
Developed by:
U-MIC
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