Ethical Governance Framework (EGF) for BioMedBridges

Carol SmeeIndependent External Ethics Advisor

Governance within terms of the EGF

Ethical Governance Committee

• Monitors compliance of the project with the EGF• Provides an ethics management report to

Executive Steering Committee• Supports the External Independent Ethics advisor

in monitoring and reporting on progress with respect to the requirements of the EGF

• Prepares updates of the EGF to be approved by Executive Steering Committee

Ethical Governance Committee

• Janet Thornton, Chair• Ruth Chadwick, University of Cardiff

(nominated by BBMRI)• Christian Gluud, Copenhagen University Hospital

(nominated by ECRIN)• Kimmo Pitkanen, Institute for Molecular Medicine

Finland (nominated by EATRIS)• Maurizio Ribera d’Alcala, Stazione Zoologica Anton

Dohrn (nominated by EMBRC)

EGF requirements• Only data for which all national regulatory

requirements have been fulfilled should be made available

• The project establishes data interoperability – it does not test scientific hypotheses (WP reports to the EU must reflect this)

• No data will be stored in BMB – data is stored by the data providers and made accessible/linked from there

• Novel ways of combining data or datasets can proceed as long as the data is linked or unlinked anonymised and an ethics committee has granted approval

EGF requirements• Responsibility for all data made

available and linked or accessed via BMB remains with data providers

• Approval for use of data will be by existing committees (DACs or, where necessary, ethics committees)

• Research participant consent and/or ethics committee approval must cover all aspects of making data available within BMB and/or accessing it in another country

EGF conditions• Consider implications of linking with new

and/or different types of data and what might be discovered

• Direct feedback of research results to research participants is not planned

• Unlinked anonymised data will be impossible to remove from the dataset

• EGF stipulates that each data provider should complete a data provider form (where appropriate) – intention is to ensure that all ethical issues re. datasets have been addressed

• Everyone has to agree to sign-up to it!

Data ProvisionTo enable data sharing, data providers are responsible for ensuring that the following (where relevant) have granted approval for the data to be accessed within BMB prior to data deposition:• Ethics committees• Data access committees• National regulatory authorities• Or equivalent bodies.Data providers are responsible for ensuring consent and/or ethics committee or other authority (where relevant) approval is in place.

Data ProvisionDeposition of data by data providers acts as assurance to the project that data providers have obtained all appropriate approvals required by:• Relevant national laws• Relevant national regulations

Ethics Committees – There to help!• Where there is doubt re. consent for use in BMB or

where consent did not foresee use of data in BMB• Where there is doubt consent covers the

combination of datasets• Where data analyses may confer non-

intentional stigmatisation of population subsets• Where existing consent does not cover sharing of data across

national boundaries (inc. source country different from data deposition country)

• Where consents do not allow for an individual’s data not to be withdrawn when requested by them to do so (and data may already be accessed by other researchers)

• What to do about communicating findings of clinical significance (not planned in BMB)

What the Coordinator Needs to Know!Data Provider Form to be used where there are restrictions on use imposed by:• Consent requirements• Ethics committee (or DAC) approvals (to

include restrictions on combining datasets)• National regulations• Agreements, e.g., MTAs, RCAs, DAAs – to include those made with

the original suppliers of the data• Time-limitations attached to datasets• Obligations re. communication of findings of clinical significance, inc.

any obligations on data requestors and time-limits.However, please note that the BMB Coordinator is not responsible for ensuring that any conditions/restrictions are complied with.

1. Name of data provider

2. Name and address of Data Provider’s research institute/university

3. Name of dataset and URL of dataset or service

4. Please list the restrictions on use imposed by consent requirements, ethics committee approvals, national regulations or any agreements, such as, research collaboration agreements, material transfer agreements, and data access agreements, including those made with other parties who may have originally supplied the data

5. Is the data obtained from the research participant in linked or unlinked anonymised?

6. If linked anonymised, name the person(s) holding the linkage key

7. If linked anonymised, please give the name and address of the linkage key holder’s research institute/university

8. If applicable, please state if there is a date by when this dataset must be removed from BioMedBridges

9. Please state any decisions made regarding the management and communication of findings of individual clinical significance, including any obligations data requestors may have to communicate findings, and any pre-set time-limits for the feeding-back of results

10. Please sign to indicate that you have read the BioMedBridges Ethical Governance Framework document and you agree to abide by the conditions contained therein

11. Please sign to confirm that the donor consent provisions and/or ethical approval, and national laws and regulations, allow the use of the data in BioMedBridges

Examples of when a Data Provider Form is needed

• A dataset in which the consent provisions only allow the use of the dataset in studies which are concerned with cardiovascular disease

• A dataset where findings of individual clinical significance are to be communicated back to research participants

Examples of when a Data Provider Form is not needed

• A dataset uploaded into an existing database which already allows combination of datasets

• A dataset generated through the use of model organisms which does not have restrictions placed upon its use

• A dataset generated from human participant data where there is broad consent and ethics committee approval to share the data openly and indefinitely for any research study

Why the Coordinator and External Ethics Adviser Need to Know!

• We will use the Data Provider Forms to ‘audit’ selected case-studies in Autumn 2014 to get a feel for how any restrictions on data use are being considered, and the project’s compliance with the Ethical Governance Framework

• We will use information from these case-studies in our report to the EU in December this year

Thank you for listening

…with thanks to Steffi Suhr for her input and excellent suggestions re. this presentation.

Contact details:Carol Smeecs14@sanger.ac.uk+44(0)1223 494968