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.

What is Protected Health Information (PHI)?

The type of data defines how it can be shared or transferred with collaborators and co-workers.

View PHI and Compliance Data Types

Which form do I need?

**All forms can be found on our Forms & Templates page under Data Access and Sharing.**

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.
  • Decedents Attestation:  Submit when you will access PHI for research, but you can verify that all individuals whose PHI will be included are deceased.

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 from KPNW to another institution? Start from the appropriate KFRI template below, complete the Agreement Cover Sheet, and send to CHR_ComplianceApprovals for review.

KFRI Contract Templates

Agreement Cover Sheet

Receiving data from another institution?  They may ask us to sign their template agreement.  Send to CHR_ComplianceApprovals for review.

KPNW Release of Information (ROI) Office

These resources are typically used when a participant in a study outside of Kaiser Permanente needs to have their KP medical record released for that study. A participant in the KP study who needs their medical records transferred to KP from another institution should check with the other institution for their paperwork requirements.