OVERSIGHT POLICY

In order to provide ongoing oversight of GAIN policies for responsible data use, the GAIN has developed both internal and external review and monitoring procedures:

The GAIN Data Access Committee (DAC) will review all requests for access to the GAIN dataset through the review of incoming Data Use Certification (DUC). The DAC will review the submitted DUC document to confirm that Requestors have agreed to the following stipulations:

• the appropriate research uses of the requested GAIN Project Dataset;
  
• the review of on-line material regarding the responsible use of GAIN data;
  
• the commitment not to seek to identify individuals within the dataset;
  
• the commitment not to distribute the data;
  
• the submission of annual reports on research activities; and
  
• the acknowledgment of the GAIN Publication and Intellectual Property policies.

In addition, the Data Use Review Board (DURB) will provide ongoing review of the data use policies with particular attention to participant protection mechanisms in order to ensure that all uses of GAIN-generated data are consistent with limitations on research use specified by Contributing Studies (e.g., restrictions stemming from participant consent documents) and adhere to the highest standards for protecting the privacy and confidentiality of participants.  The DURB may address topics such as, but not limited to:

• GAIN data management procedures; 
  
• investigator provided information on the use of GAIN data;
  
• GAIN oversight activities to monitor compliance with the GAIN data access and use and publication policies; and
  
• any untoward effects of access of GAIN data that had been identified; e.g. attempts to identify individual subjects.