The Juvenile Justice Professional's Guide to
Human Subjects Protection and the IRB Process
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Privacy Certificate
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Privacy Certificate
Information Transfer Agreement
The Privacy Certificate is a written certification of the policies and procedures that the researcher or research organization utilizes to protect the confidentiality of identifiable youth information in research and statistical activities. Specific criteria apply to the collection, storage, use, transfer, reporting, and publication of these youth data. All research funded by Federal funds must submit a Privacy Certificate as a condition of approval of a grant application or contract proposal when information identifiable to a private person will be utilized for a research or statistical project.

In order to demonstrate compliance with the regulations, the Privacy Certificate must include a description of the project and the following assurances from the researcher or research agency.
  • Information identifiable to a private person will be used only for research and statistical purposes.

  • Data identifiable to a private person will not be used or revealed except as authorized in the regulations.

  • Access to the data is limited to only employees having a need for the data and that such employees shall be advised and agree in writing to comply with the regulations.

  • All contractors, subcontractors, and consultants requiring access to identifiable data will agree, through conditions in their contracts, to comply with the regulations.

  • Adequate precautions will be taken to insure administrative and physical security of identifiable data and to preserve the confidentiality of personally identifiable information.

  • A log will be maintained indicating to whom identifiable data have been transmitted and that such data have been returned or alternative arrangements have been agreed upon for future maintenance of the data.

  • Project plans will be designed to preserve anonymity of private persons to whom the information relates, including, when appropriate, statistical disclosure methods.

  • Project finding and reports prepared for dissemination will not contain information which can reasonably be expected to be identifiable to a private person except as authorized under the regulations.

  • All project personnel will be advised about and agree in writing to comply with all of the regulatory procedures to protect privacy and confidentiality of personally identifiable information.

  • The Privacy Certification shall include a description of the physical or administrative procedures to insure the security of the data which must include:

    • A description of the project, the project objectives, and the research and statistical component of the project.
    • Procedures to notify research subjects from whom identifiable data are collected or obtained and, when notification is to be waived, the justification for the waiver in accordance with criteria outlined in the regulations.
    • Procedures designed to preserve confidentiality of personally identifiable information.
    • Justification and rationale for collection of data in identifiable form, when applicable.
    • Procedures for data storage.
    • Procedures to insure the physical and administrative security of data including the removal of identifiers from the data set and the separate maintenance of a name-code index in a secure location.
    • Procedures for the final disposition of data upon completion of the research project including physical destruction and removal of identifiers.
    • List of names of all employees with access to the data including the principle investigator, the project staff, and contractors/subcontractors/consultants.
    • Name and title of individual with the authority to transfer data to a researcher or agency.
    • Written policies on the transfer of data in identifiable and non-identifiable format.

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