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OSDC Protected Data Handling Requirements and Training

This is a final reminder about the Atwood migration taking place tomorrow and the CITI training we need from you to continue your access once Atwood is back online. As a reminder - if we have not received the proper certification from you by this Thursday 12.11 when Atwood maintenance is complete, you will be locked out.

###Atwood - Handling Sensitive Data Training: Second, we will be asking all Atwood resource allocation recipients to provide us copies of the standard training and organizational approvals that all projects that use protected health information and other sensitive data must have. After the maintenance period is complete, recipients of Atwood resource allocations will not be allowed to use the Atwood resource unless we have copies of the required materials.

The details are below. If you have any questions, please don’t hesitate to contact us.

Before detailing the documentation we require, we remind you that the Atwood Protected Data Cloud provides a computing environment designed to support research with protected health information and other sensitive data, but the computing environment is only one component of what is required to properly secure protected health information or other sensitive data.

Another important requirement is that those using a computing infrastructure like Atwood have proper training and have received from their institution all the required approvals for working with protected health information and other sensitive data.

We are requesting the following documentation:

  1. For each project, that the PI of the project send us a copy of the IRB approved protocol for the study using the Atwood Protected Data Cloud or a letter showing the study is exempt from needing an IRB Protocol. The IRB Protocol or Exemption should be from the home institution of the PI for the project. For new protocols or renewals of protocols, please refer explicitly to the Atwood environment.

  2. For each researcher with a Atwood Protected Data Cloud account, a certificate proving that the researcher has completed CITI training appropriate for working with Protected Health Information or other sensitive data. A copy of a certificate indicating that you have completed the required CITI training will be requested each year.

After Atwood comes back on line, we will also be requesting:

  1. That you re-certify that you will properly protect research data in Atwood. Specifically,
  • that you will not ever connect from an Atwood virtual machine directly to the Internet (but instead all connections will always go through the Atwood Head Node)
  • that all protected health information is always transported in an encrypted form;
  • that if any protected health information or other sensitive data is ever removed from Atwood, then it is transported in an encrypted form to another computing environment that has been approved by your home institution for storing and managing sensitive data; and
  • that you will not defeat or circumvent any of the mechanisms that Atwood employs for protecting and securing data, include proxies and head nodes.
  • This re-certification will be done by reading an online notice and indicating that you will honor the Atwood usage agreement.

###About CITI Training:

Please complete the following five courses from CITI training by December 11th, 2014.

  • Basics of Health Privacy
  • Health Privacy Issues for Researchers
  • Responsible Conduct of Research (RCR) Basic
  • Human Subjects Research – Biomedical (Biomed) Modules
  • Basics of Information Security, Part 1
  • Basics of Information Security, Part 2

Here are some details:

  • Go to CITI home page: www.citiprogram.org
  • If you do not already have a CITI account, go to "Create an account" --> Register and select your Organization Affiliation. Be sure to select your home institution as your “Participating Institution,” select a username/password, and fill out all other necessary information requested in registration.
  • Once this is completed you will be required to complete 4 enrollment questions. This will determine the modules you will need to complete.
  • Please make the following choices:
  • Would you like to take the Conflict of Interest Course? - "Yes"
  • Select your Division at your Institution.
  • Researchers involved in protocols need to complete CITI Basic/Refresher - "Need to Enroll for Research Staff"
  • Responsible and Ethical Conduct of Research course - "Yes"
  • Once complete, send your certificate and OSDC username to [email protected]
  • Please make sure and complete this process by the December 11th, 2015 or your resource allocation will be suspended.

Thank you, Robert Grossman Center for Data Intensive Science University of Chicago