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Update: Evaluation of the CIHR Privacy Best Practices document

After broad-based consultations in 2004 led by a multi-sectoral Privacy Advisory Committee, the Ethics Office published Best Practices for Protecting Privacy in Health Research in September, 2005.

The Privacy Best Practices document was intended to:

  • provide guidance for health researchers in the design and conduct of health research involving personal information;
  • be a resource for research ethics boards and institutions to consult when reviewing and evaluating such research; and
  • contribute toward a more harmonized legal and policy framework for addressing privacy and confidentiality issues in health research.

The Privacy Advisory Committee made a number of recommendations for the implementation of the Privacy Best Practices document, including that the document be evaluated and revised in two years' time. At that time, the Privacy Advisory Committee envisioned that the document would become mandatory CIHR funding policy, and be referred to the Interagency Advisory Panel on Research Ethics with a view to the document being integrated in revised form into the Tri-Council Policy Statement: Ethical Conduct in Research Involving Humans (TCPS).

In response to the Privacy Advisory Committee recommendations, the Ethics Office established and chaired an Initial Implementation Working Group (IIWG). From 2005 to 2007, the IIWG sought feedback from research ethics boards, researchers, the ethics community and other stakeholders through targeted telephone interviews, focus groups, and an online survey. Most of those surveyed supported the Privacy Best Practices document remaining a voluntary educational resource, rather than becoming mandatory CIHR policy.

Based on the feedback received during the two year implementation period, the IIWG recommended that:

  • the document be referred to the Interagency Advisory Panel on Research Ethics for consideration as a voluntary educational companion document to the TCPS;
  • the educational value of the document be promoted widely and complemented by various teaching tools;
  • communication efforts be intensified and broadened, and be ongoing to ensure that the research community is notified of any changes to the document;
  • no major revision to the document be done at this point; however the electronic format of the document should be improved by adding hyper-links, selective printing capability, as well as thumbnail tabs;
  • a long-term implementation strategy assessing the comparability of the document with international guidance documents and fostering international acceptance; and
  • CIHR liaise with the Interagency Advisory Panel on Research Ethics and its Social Sciences and Humanities Research Ethics Special Working Committee, to encourage the use of the Privacy Best Practices document by social scientists.

The Ethics Office presented these recommendations to CIHR's Standing Committee on Ethics (SCE) for endorsement in March 2008. The SCE endorsed the recommendations, in particular the Working Group's recommendation that the CIHR Best Practices for Protecting Privacy in Health Research (2005) document be promoted as a voluntary educational Tri-Council resource.

This endorsement was subsequently referred to the Interagency Panel on Research Ethics (PRE) for consideration as a voluntary educational companion document to the TCPS.

The Interagency Panel on Research Ethics has included in the draft 2nd edition of the TCPS a reference to the CIHR Privacy Best Practices. The Panel will issue a final draft of the 2nd edition for consideration by the Agencies in the summer of 2009.

Regarding the other recommendations presented in the IIWG report, their implementation will be phased in, based on priority and availability of resources.