CIRTL Data Sharing 10/9/15

New Opportunities The CIRTL Network Commons (CNC) offers the potential for easier access to data for evaluation purposes. The CNC will automatically track much of what CIRTL Central has been doing through forms and excel files. (Replacing the Institutional Portraits forms!!) As Ann noted yesterday, we see the data collected through the CNC as “Network” data to be cared for and used by the Network, with appropriate protections for participants.

Data Sharing Agreement - Advice from UW IRB: The best course of action would be to establish a Memorandum of Understanding among all CIRTL partners that covers data sharing procedures. (non- human subjects data) The data sharing agreement would likely include broad language on sharing non-identifiable user data collected through the CIRTL Network Commons. The MOU would also cover how individual research studies based on data collected through the CNC would be handled.

Data Sharing Agreement Ideally, the MOU would be broadly written. If the potential for future federal funding exists, it is important that the language in the MOU and in any IRB protocols align with the text of the grant proposal. If a proposal is funded with language that does not align with the MOU, it may be necessary to revise all of the MOUs.

Preparing for two scenarios 1.Institutional leaders or their designees have automatic access to an agreed upon set of data collected through the CNC. For example: De-identified, aggregate, participation data Program offerings details (descriptions, schedule, history) Number of Associates, Practitioners and Scholars 2.A system is put in place to review and handle requests for access to CIRTL members or CIRTL data for research projects that go beyond the scope of the data sharing agreement. (Research Committee)

Potential Topics to include in MOU: 1. How a CIRTL Research Committee would need to approve any research studies (prior to IRB) 2. Establishment of local IRB jurisdiction for investigator-led studies 3. Permission for data to be stored on computers owned or rented by a 3 rd -party vender (data security measures) 4. Use and access to the data by employees of any 3 rd party contractors (potential conflicts of interest, use of data) 5. Designation of the individuals/role of people within the Network who may access and use aggregate user data for their own and other CIRTL network institutions. 6. Issues related to FERPA, as appropriate 7. Other

User Agreement The CIRTL Network Commons would need to have a user agreement that all site-users must agree to in order to create an account on the site. The user agreement should broadly describe what data will be collected, who has access to the data and any restrictions on how the data will be used. The user agreement should explain that data would not be used for research purposes without the implementation of a separate consent procedure.

Progress to date Series of conversations with representatives from the ISU and UW IRB. Discussions among members of the CNC Team, Ann Austin, Kitch Barnicle A draft data sharing agreement prepared by, Jim Lyne, an attorney at WCER. We need input/feedback from the Network.

Next Steps wrt to Agreement: 1.Looking for a few volunteers to carefully review the draft data sharing language. 1.Looking for a full Network review by November 30th (??), following by the collection of signatures. Note: The current MOUs run through June 2017

Handling Requests regarding Research related to CIRTL Requests for access to CIRTL members or CIRTL data for research projects (that go beyond the scope of the data sharing agreement) are likely to increase. The source of requests could be internal or external to the Network.

Potential Issues for Consideration: The time/burden for those studied (participants, institutional leaders, faculty/staff) The time/burden on CIRTL Central The need to coordinate plans for related projects Ownership of data and study outcomes Intended uses of research Quality of research

Steps Forward: Establish a CIRTL Network Research Committee Charge: Identify the issues Develop and recommend policies and procedures to guide CIRTL response to requests Develop a protocol of for prospective researchers about applying for approval and conducting research relevant to CIRTL