the need for data sharing in rare disease research

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Istituto Superiore di Sanità Rome (Italy), September 26-28, 2016 4th International Summer School on Rare Disease and Orphan Drug Registries The need for Data Sharing in Rare Disease Research Paola De Castro, Sabina Gainotti National Institute of Health, Rome, Italy Publication, Accessibility and Informed Consent 1

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Page 1: The need for data sharing in Rare disease research

Istituto Superiore di SanitàRome (Italy), September 26-28, 2016

4th International Summer School on Rare Disease and Orphan Drug Registries

The need for Data Sharingin Rare Disease Research

Paola De Castro, Sabina Gainotti

National Institute of Health, Rome, Italy

Publication, Accessibility and Informed Consent

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4th International Summer School on Rare Diseases, ISS, Rome, 26-28 Sept. 2016

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Short introduction

Two speakers different backgrounds

Some theory, lessons from

experience, practical tips

Questions & discussion

How to benefit from this lesson?

Page 3: The need for data sharing in Rare disease research

Main issues in RD Research

• Many rare diseases (6000-8000)

• Few patients, specialists, data, bioresources

• High motivation in the patient community

• Special vulnerability of patients

• Need/Obligation to make the best use of available resources AND protect patient integrity

4th International Summer School on Rare Diseases, ISS, Rome, 26-28 Sept. 2016

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Data sharing: 3 key benefits

• Faster progress in improving health

• Better value for money

• Higher quality science

• A necessity in the field

of RD research!

4th International Summer School on Rare Diseases, ISS, Rome, 26-28 Sept. 2016

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Strategic role of scientific communication

WHY IS IT SO IMPORTANT?

• What is your target?

• How do you disseminate your research/data?

• Are you aware of existing (editorial) rules?

• Are you aware of ethical issues?

4th International Summer School on Rare Diseases, ISS, Rome, 26-28 Sept. 2016

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Some points to consider:

WHY is sharing is important

Communication (sharing) is an essential part of research4th International Summer School on Rare Diseases,

ISS, Rome, 26-28 Sept. 2016

Progress is always based on previous work

Scientists have a responsibility for communicating research

results

Patients need to be informed

All stakeholders (policy makers, general public)

should be aware of the value of scientific research

Health is a common good

We live in a “global” world

Duplication allows to reduce waste

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journal articles

technical reports

oral communications or posters

in conferences or workshops

abstracts and proceedings

social media

repositories

etc.

researchers,

medical

& technical staff

patients, families, policy

makers, community health

workers, vendors, etc.

oral communications

leaflets, bookmarks, posters

audiovisuals

workshops, informal meetings

e-health communication

social media

networks

dynamic consent

etc.

PEERS LAY PEOPLE

share research results, progress

in research, contribute to debate

change behaviour, improve life style,

access to therapy, increase retention

type

objective

target

Different targets, objectives & types

of scientific communication

4th International Summer School on Rare Diseases, ISS, Rome, 26-28 Sept. 2016

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Open sharing of research activity

Open online information

Open Access journals

Open peer-review

Open data sharing

Open to patients/society

Open in disclosure conflicts of interest

Open online courses (MOOCs)

WHAT DOES IT MEAN?

A NEW STATE OF MIND

New trends: BE OPEN!

4th International Summer School on Rare Diseases, ISS, Rome, 26-28 Sept. 2016

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• PLOS

• NIH

• European Commission

• Wellcome trust

• Telethon

• Italian research institutes

• …..

• The European Commission

National and international institutions and funding organizations

support OA to research information and data

Issue policies and recommendations with varying embargo periods, as from 2000

OA, a moral imperative and a rule

Not only publications data

4th International Summer School on Rare Diseases, ISS, Rome, 26-28 Sept. 2016

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OPEN DATA

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FROM OPEN ACCESS

TO RESEARCH PUBLICATION

TO OPEN DATA

OA Declarations

OA Policies

OA MandatesOPEN SCIENCE

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OA routes

2600 listings

>9000 journals

CREATE AWARENESS

among all stakeholders

Digital archives (green)

OA journals (gold)

OA is a philosophy and not an archive

4th International Summer School on Rare Diseases, ISS, Rome, 26-28 Sept. 2016

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Check what the publisher allows to do with yoour paper

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https://vimeo.com/151882443

Be aware

of predatory

journals

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It provides true immersion

in the contest of the subject matter.

Data are linked to databases

providing the most updated

information

It proves a positive correlation

among data sharing,

citations and impact.

The article of the future5 minute video by Elsevier

It shows the advantages

of enriched articles including

supplementary information

interactive content.

4th International Summer School on Rare Diseases, ISS, Rome, 26-28 Sept. 2016

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Disseminate and Sharre (online, print, social, talks,

links, repositories, etc.)

Plan your work in advance

Select the best type of communication (target, objective, context)

Consider time and resources available

Define authorship & responsibilities (collaborators)

Consider previous work (bibliographic search)

Follow instructions to authors (if available)

Produce a first draft

Revise the draft, seek advice, share, test the product

Submit for publication (peer review process)

Approve final draft

GENERAL ADVICE for researchersTo get your article published

SELECT the right OA journal (DOAJ)

READ the Instructions to authors

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• Guidelines

• Peer review

• Impact factor

• Open access and open science

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Challenges of dissemination

Organised by Istituto Superiore di SanitàRome (Italy), September 26-28, 2016

... Would you like to publish more? Whose

task is this?

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Ethical considerations applying

to scientific publications

also apply to research data

Discussion

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You need to publish

You need to share data

WHY NOT?A survey on researchers’ attitude towards data sharing will be launched in

Italy, following Researchers and their data. Results of an Austrian survey.

Report 2015 https://blogs.openaire.eu/?p=619)

The topics of the survey were:

– Data types and formats;

– Data archiving, backup and loss;

– Ethical and legal aspects;

– Accessibility and subsequent use;

– Infrastructure and services.

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Promoting the culture of open science

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….there is an ethical obligation to responsibly share data generated by

interventional clinical trials because

participants have put

themselves at risk.

Many funders around the world —foundations,

government agencies, and industry — now

mandate data sharing.

ICMJE Supporting Open data sharing

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4th International Summer School on Rare Diseases, ISS, Rome, 26-28 Sept. 2016

22http://www.ease.org.uk/wp-content/uploads/data-sharing-statement.pdf

EASE statement on data sharing

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The post-grant Open Access Pilot

covers OA Article Processing Charges

(APCs) for FP7 projects up to two

years after they end.

Funded publications must be peer-reviewed and be made

available under a CC-BY licence where possible.

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Open up

publicly funded

research data

December 2013

European

Commission

Data

Management

Plans required4th International Summer School on Rare Diseases,

ISS, Rome, 26-28 Sept. 2016

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254th International Summer School on Rare Diseases,

ISS, Rome, 26-28 Sept. 2016

International Rare Disease Research Consortium

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H2020 Programme

Guidelines on FAIR

Data Management

in Horizon 2020

July 2016

OPEN ACCESS

• For publications is an obligation

• For data the Commission is

running a flexible pilot

Data Management plan for research data to be FAIR:

Findable, Accessible, Interoperable and Reusableto ensure it is soundly managed.

Good research data management is not a goal in itself,

but rather the key conduit leading to

knowledge discovery and innovation,

and to subsequent data and knowledge integration and reuse.

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Takes into account the need

to balance openness and

• protection of scientific information,

• commercialisation and

• Intellectual Property Rights (IPR)

• privacy concerns

• security

• data management

• preservation.

Open Research Data Pilot – ORD PILOT

Initially only selected areas

from 2017 all thematic areas

Encourages sound data management

as an essential part of research best practice.

Data Management Plan (DMP) is a deliverable to be submitted at month 6

A template is available

“as open as possible,

as closed as necessary"

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Biobanks as an example

Standard citations of bioresources

in journal articles to evaluate their impact

A multidisciplinary project involving researchers and editors

COBRA guidelines

How to recognize the value

and impact of data sets?

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4th International Summer School on Rare

Diseases, ISS, Rome, 26-28 Sept. 2016

The neglected roleof research biobanks

In scientific publications biobanks are

• Not cited at all

• Cited in a heterogeneous way

• Not cited in a standardized way

• Difficult to retrieve

What is needed • Sensitize journal editors to BRIF issues

• Standardize citations in journal articles

• Modify editorial guidelines

• Inform the scientific community about the relevance of

this issue

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Difficult to evaluate

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A GUIDELINE TO STANTARDIZE CITATION

OF BIORESOURCESPublication of the CoBRA guideline, BMC Medicine 2015

Highly accessed article

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Elena Bravo, Europe Biobank Week, September 2016

Many items apply

to all data sharing

initiatives

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Still some work to be

done....

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Data sharing: main advantages

• re-analysis of data to verify results, independent scrutiny

• New discoveries in old data sets

• long-term preservation, data integrity

• Re-collection of data minimized, use of resources optimized

• Replication studies as training tools

4th International Summer School on Rare Diseases, ISS, Rome, 26-28 Sept. 2016

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BUT…. Empty archives

Data lying on personal hard drives and CD.

Researchers not annotating datasets with rich metadata and losing access and understanding of the original dataset

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• ID-Cards

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Share your data: ID-Cards

... What would limit your participation?

What would convince you?

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38Organised by Istituto Superiore di Sanità

Rome (Italy), September 26-28, 2016

Data sharing by scientists: practices and perceptions. Tenopir et al. Plos One 2011;6(6):e21101

... Are we missing any reason?

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Privacy: main barrier to data sharing?

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An age of collaboration: global data and global research

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Mission: accelerate progress in human health by helping to establish a common Framework of harmonized approaches to enable effective and responsible sharing of genomic and clinical data and to catalyze data sharing projects that drive and demonstrate the value of data sharing.

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Much research data about people—even sensitive data—can be shared ethically and legally if researchers employ:

•strategies of informed consent•anonymisation •controlling access to data

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• At the time of data/samples collection, their future specific use may still not be foreseen

• In broad consent, an individual gives consent to widely specified research (cancer research, RD research), which allows for many future uses of tissue and data

• Broad time frame

• Broad geographical frame

4th International Summer School on Rare Diseases, ISS, Rome, 26-28 Sept. 2016

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Broad consent

Organised by Istituto Superiore di SanitàRome (Italy), September 26-28, 2016

... Would you give broad consent for

the use of your tissues/data? What the pros and cons?

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Broad consent: is it acceptable?

• Proper on-going ethical and legal oversight are in place (e.g. approval by a research ethics committees for new projects).

• There is a right to withdraw (?)

• There are mechanisms to update research participants on the use of their data/samples.

4th International Summer School on Rare Diseases, ISS, Rome, 26-28 Sept. 2016

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47Organised by Istituto Superiore di Sanità

Rome (Italy), September 26-28, 2016

Dynamic Consent

Dynamic Consent is a new approach for engaging individuals about the use of their personal information. It is also an interactive personalized interface that allows participants to engage as much or as little as they choose and to alter their consent choices in real time.

Jane Kaye et al. Dynamic consent: a patient interface for twenty-first

century research networks. European Journal of Human Genetics (2014), 1–6

4th International Summer School on Rare Diseases, ISS, Rome, 26-28 Sept. 2016

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48Organised by Istituto Superiore di Sanità

Rome (Italy), September 26-28, 2016

What makes Dynamic Consent ‘dynamic’?

• It allows the same samples/information to be (re)used with the knowledge and consent of the individual.

• It enables individuals to give and revoke consent in response to their changing circumstances.

• It allows people to be approached for different kinds of research or to obtain their opinions as new research projects are started and new ethical questions arise.

• Consent preferences can be modified

over time.

... Would you like to be updated on the

use of your tissues/samples?

What the pros and cons?

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The problem with old collections

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Anonymisation... The right solution?

• De-identification and re-identification of individual data

• Genetic information is shared among a same family or group

... Is anonymisation the right solution? What the pros and

cons?

4th International Summer School on Rare Diseases, ISS, Rome, 26-28 Sept. 2016

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Governance framework

• Good governance underpins a system of data sharing that depends on trust

• Federated systems (registry doesn’t loos control of data)• From “ownership” to “custodianship”• Controlled access by: Accreditation of researchers; Unique

identifiers for researchers; Data Access Committees; Research Ethics Committees; Data Access agreements.

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• Data Transfer Agreement (DTA)/Material Transfer Agreement (MTA): DTAs and MTAs should always be used to govern data/material transfer between parties.

• DTAs and MTAs are legal contracts that help ensure that the parties signing the agreement will comply with a set of rules defined by the involved parties. These documents state the scope of the use of data or bio-specimens, the limits posed by the informed consent used for the original collection, special limitations, duration of sharing and use, and other special conditions including donors’ expectations, etc.

Data access/transfer agreements

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Data access agreements

• Access agreements must be drafted clearly, so that researchers and their institutions are aware not only of their obligations, but also that “the border between acceptable and unacceptable conduct be clearly delineated and predictable.

• Explicit sanctions are important in order to respond effectively to any breach. These sanctions must be balanced—harsh enough to deter abuse by researchers and yet not to discourage access.

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Coming into effect Spring 2018

Same rules for all EU Members4th International Summer School on Rare

DiseasesISS, Rome, 26-28 Sept. 2016

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Article 9: Processing of special categories of personal data

1. The processing of personal data, (…) genetic data or data concerning health or sex life (…) shall be prohibited.

2. Paragraph 1 shall not apply where:

(a) the data subject has given consent to the processing of those personal data,

(…)

(h) processing of data concerning health is necessary for health purposes and subject to the conditions and safeguards referred to in Article 81; or

(i) processing is necessary for historical, statistical or scientific research purposes subject to the conditions and safeguards referred to in Article 83;

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What’s new for citizens

A "right to be forgotten": When an individual no longer wants her/his data to be processed (…) the data will be deleted.

Easier access to one's data: Individuals will have more information on how their data is processed and this information should be available in a clear and understandable way. A right to data portability will make it easier for individuals to transmit personal data between service providers.

The right to know when one's data has been hacked: Companies and organisations must notify the national supervisory authority of data breaches and communicate to the data subject all high risk breaches as soon as possible so that users can take appropriate measures.

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What’s new for citizens

Data protection by design and by default: Data protection safeguards will be built into products and services from the earliest stage of development, and privacy-friendly default settings will be the norm

Stronger enforcement of the rules: data protection authorities will be able to fine companies who do not comply with EU rules up to 4% of their global annual turnover.

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What’s new for Research

More “relaxed” towards secondary uses

Recital 33: It is often not possible to fully identify the purpose of personal data processing for scientific research purposes at the time of data collection. Therefore, data subjects should be allowed to give their consent to certain areas of scientific research when in keeping with recognized ethical standards for scientific research.

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What’s new for Research• More “relaxed” towards secondary uses

Recital (50): The processing of personal data for purposes other than those for which the personal data were initially collected should be allowed only where the processing is compatible with the purposes for which the personal data were initially collected.

Art 5:1(b) further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);

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CHAPTER III -Rights of the data subjectArticle 12: Transparent information,

communication and modalities for the exercise of the rights of the data subject

1. The controller shall take appropriate measures to provide any information (…) relating to processing to the data subject in a concise, transparent, intelligible and easily accessible form, using clear and plain language(…)

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Content of the information (Article 13)

• controller’s identity and contact information

• intended purposes of the processing activities

• possibility that the data will be transferred to another entity or to a third country where applicable

• data subject’s rights to access, rectification, erasure and to object to processing

• period for which the personal data will be stored, or the criteria used to determine that period.

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Article 14: Information to be provided where personal data have not been obtained from the

data subject

• An updated notice should be provided where a controller intends to further process data for a different purpose, including for research. Under Article 13(3), the subsequent notice must include both the new research purpose and the elements laid out in Article 13(2), which mainly concern the data subject’s rights with regard to her data.

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Article 14: Information to be provided where personal data have not been obtained from the

data subject• a researcher may be exempt from the notice

requirement if she received the personal data from someone other than the data subject, such as where the data came from a publicly available source. Article 14 exempts controllers in these circumstances, if “the provision of such information proves impossible or would involve a disproportionate effort,” which "could in particular be the case” in the research context.

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Exemption to notify (Article 14(5)(b)).

• A researcher also may claim exemption if providing notice would be “likely to render impossible or seriously impair the achievement of the [research] objectives,” provided there are appropriate safeguards in place, “including making the information publicly available”

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Exemption form the right to erasure and right to object

• the Regulation exempts research from the right to erasure if it is “likely to render impossible or seriously impair the achievement of the [research] objectives” (Article 17(3)(d)).

• A researcher may override a data subject’s objection to processing if “the processing is necessary for the performance of a task carried out for reasons of public interest” (Article 21(6)).

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Transferring personal data to third countries for research purposes

permitted if :

The country offers an “adequate level of protection” as determined by the European Commission (Article 45(1)).

Controller has implemented specific safeguards, including Binding Corporate Rules and standard contractual clauses

Data subject has provided explicit consent after being informed of the risks related to the transfer (Article 46(2); Article 49(1)(a)).

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Looking forward….

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