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Data Security Review Pilot Beginning June 1, 2019

May 13, 2019

Harvard's Research Data Security Policy requires all research that receives a data security level (DSL) assignment of 3, 4, or 5 be reviewed by a School Security Officer (SSO). Historically, DSL 3 has been reviewed within a one-year time frame, while SSO review of DSL 4 and DSL 5 has been required prior to IRB approval. With the recent changes to the federal regulations governing human subject protections, many studies that received a DSL 3 used the continuing review timepoint as a “due date” for the DSL 3 review. As continuing review is no longer a requirement for many studies, a working group has been thinking about ways to revisit this practice.

Starting June 1, 2019, and lasting through the summer, a pilot of a revised SSO-practice will take place. Studies that receive a DSL 3 will follow the review practice of DSL 4 and DSL 5 – SSO review will be required before IRB approval.
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