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NIH Data Management & Sharing (DMS) Policy

Considerations for Human Subjects Data

Can data derived from human participants be shared?

Data from human participants may be shared in ways that are consistent with consent practices and applicable law. The NIH policy encourages investigators to consider the following three concepts while determining what degree of sharing (if any) is appropriate:

  1. Incorporation of data management and sharing language into informed consent processes
  2. Clear communication to repositories and their users of how data may be reused and any limitations on reuse
  3. Whether controlled access to data is necessary, in addition to existing protective practices (e.g. deidentification, Certificates of Confidentiality)

Additional Resources

NIH Guidance:

OSU Guidance & Policies:

Informed Consent for Data Sharing:
(in addition to the NIH guidance above)

De-identification:

 

Examples: