While the materials provided by the NIH can provide some helpful guidance, be mindful that those materials are created for a very wide audience and do not consider local UVM/UVMHN institutional policies. All DMS plans submitted to the NIH must comply with University of Vermont policy:
Does the DMS Policy expect that when consent is obtained for research involving human participants, it must be for sharing and the future use of data?
No. Informed consent for participation in research remains the cornerstone of trust between researchers and research participants and thus the DMS Policy does not dictate how this process is achieved. Rather, researchers’ intention for scientific data management and sharing, as proactively described in Plans, is strongly encouraged to be part of the informed consent process. The DMS Policy does not expect that informed consent given by participants will be obtained in any particular way. For example, a study may plan to utilize consent for broad sharing of identifiable private information (e.g., the broad consent provision of the Common Rule at 45.CFR.46.116(d))) but it is not required by the DMS Policy.
***UVM/UVMHN is not implementing the broad consent provision as this would require prospective consent for all leftover specimens from clinical care. This would have required the hospital to create systems to track the consent data on an institutional level.***
Researchers also should be aware that they may be subject to other requirements or particular expectations, for consent, such as the NIH Genomic Data Sharing Policy.
(NIH; updated 7/26/22)
What steps does the DMS Policy take to ensure institutions and researchers protect research participants?
Award recipients must comply with any applicable laws, regulations, statutes, guidance, or institutional policies related to research with human participants and that protect participants’ privacy. The DMS Policy encourages respect for participants by encouraging researchers and award recipients to:
(NIH; updated 1/25/22)
When working with human participant data, including de-identified human data, here are some additional characteristics to look for: