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Sharing Data

Data Access and Sharing

Data Commitments Tracking

KPNW research projects make data commitments to collaborating institutions to share, destroy, or secure data on behalf of the organization. The Data Commitments Tracking System is the mechanism by which the Center for Health Research tracks and maintains these commitments.

The system is also used to track the agreements that define how the data commitments are to be carried out, including Data Use Agreements (DUAs) and other types of contracts.

Data Transfer Requests (DTRs) allow Compliance and IT Security to verify that disclosures of data to collaborators are consistent with the commitments for the project and compliant with applicable law, regulation, and policy.  All DTRs are submitted, reviewed, and approved through Data Commitments Tracking.

More information:

NOTE: The Tracking System and User Guide are only available to CHR employees.  If you are a researcher in the KPNW delivery system, please work with your CHR collaborator to complete any required data commitments tracking.  If you are sending data outside the KPNW region and do not have a CHR collaborator, please contact CHR_ComplianceApprovals@kpchr.org.

Need assistance? Have questions? See related policies under “Privacy” on the Policies and Guidance page or email CHR_ComplianceApprovals@kpchr.org.

Which form do I need?

Flow Chart: Sharing Data Requirements Overview

The flow chart shows the steps to obtain compliance approval to share data outside KPNW based on the level of identifiability.

Table: Privacy Rule Documentation for Research

This table provides a complete list of compliance and agreement requirements based on the level of identifiability and the recipient.

Other Forms

  • Prep to Research:  Submit when you need to access PHI to prepare a research protocol or, in some cases, to identify potential subjects for recruitment.  PHI may not leave KPNW under this type of permission. Find the form here.
  • Decedents Attestation:  Submit when you will access PHI for research, but you can verify that all individuals whose PHI will be included are deceased. Find the form here.

Instructions: Agreements for Specimen and Data Sharing

There usually needs to be some type of agreement in place in order to share specimens or data with collaborators at another institution.

Sending data and/or specimens from KPNW to another institution?

Select the appropriate KFRI template from KFRI Contract Templates.

Once populated with the study-specific information, submit the agreement to CHR_ComplianceApprovals@kpchr.org for compliance review and contract negotiation facilitation. DO NOT submit agreements directly to the signatory. This process ensures that each study’s agreements are maintained and tracked within our Tracking Research Agreements and Contracts (TRAC) system and each agreement is reviewed by KFRI.

Include the following information in your email submission:

  • Principal Investigator
  • Study Title
  • IRBNet number
  • Agreement Type: (DUA, DTA, MDTA, etc.)
  • Site(s) signing the agreement
  • ProBud number
  • Name and contact information of other institution’s agreement negotiator

Please also include any other information that may be helpful when reviewing this agreement (such as, this is a new agreement, an amendment to a previously approved agreement, the agreement has been revised and what changes were made, etc.).

Receiving data from another institution?
They may ask us to sign their template agreement. Send to CHR_ComplianceApprovals for review and facilitation following the same steps as above.

Need to amend a previous agreement?
Contact CHR_ComplianceApprovals for guidance and an appropriate template. Include the original agreement in your email.

Questions?
Reach out to CHR_ComplianceApprovals at any time during this process for guidance and assistance.

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Copyright 2022, Kaiser Permanente Center for Health Research

Kaiser Permanente identifies financial conflicts of interest (FCOI) and other situations that may give rise to conflicts of interest, and addresses such situations to ensure research decisions made are in the best interests of KP, its research participants, patients, and members. Kaiser Permanente operates in accordance with federal regulations addressing research financial conflicts of interest through our Policy on FCOI in Research.