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Appendix K - Certificate of Confidentiality
ICR 201807-0970-016 · OMB 0970-0523 · Object 84593701.
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6710B ROCKLEDGE DRIVE Rm 2158 Bethesda, MD 20817 5/16/2018 MDRC Ms. Carolyn Hill 16 E 34th Street 19th Floor New York, NY 10016 Dear Ms. Hill, Enclosed is the Confidentiality Certificate, protecting the identity of research subjects in your singlesite/single-protocol project entitled “Understanding Poverty: Childhood ad Family Experiences”. Please note that the Certificate expires on 07/30/2019. Please be sure that the consent form given to research participants accurately states the intended uses of personally identifiable information and the confidentiality protections, including the protection provided by the Certificate of Confidentiality with its limits and exceptions. If you determine that the research project will not be completed by the expiration date, 07/30/2019, you must submit a written request for an extension of the Certificate three (3) months prior to the expiration date. If you make any changes to the protocol for this study, you should contact me regarding modification of this Certificate. Any requests for modifications of this Certificate must include the reason for the request, documentation of the most recent IRB approval, and the expected date for completion of the research project. Please advise me of any situation in which the certificate is employed to resist disclosure of information in legal proceedings. Should attorneys for the project wish to discuss the use of the certificate, they may contact the Office of the NIH Legal Advisor, National Institutes of Health, at (301) 496-6043. Correspondence should be sent to: Dennis Twombly Ph.D. 6710B ROCKLEDGE DRIVE Rm 2158 Bethesda, MD 20817 Sincerely, Approved Date: 05/16/2018 Dennis Twombly Ph.D. Deputy Director OEP Eunice Kennedy Shriver National Institute of Child Health and Human Development CONFIDENTIALITY CERTIFICATE CC-HD-18-136 issued to MDRC conducting research known as "Understanding Poverty: Childhood ad Family Experiences" In accordance with the provisions of section 301(d) of the Public Health Service Act 42 U.S.C. 241(d), this Certificate is issued in response to the request of the Principal Investigator, Ms. Carolyn Hill, to protect the privacy of research subjects by withholding their identities from all persons not connected with this research. Ms. Carolyn Hill is primarily responsible for the conduct of this research, which is funded by: 1. Other DHHS agency:ACF, OPRE Under the authority vested in the Secretary of Health and Human Services by section 301(d), all persons who: 1. are enrolled in, employed by, or associated with MDRC and its contractors or cooperating agencies, and 2. have in the course of their employment or association access to information that would identify individuals, who are the subjects of the research, pertaining to the project known as “Understanding Poverty: Childhood ad Family Experiences”. 3. are hereby authorized to protect the privacy of the individuals, who are the subjects of that research, by withholding their names and other identifying characteristics from all persons not connected with the conduct of that research. The goal of the Childhood and Family Experiences Study is to understand the perspectives of both low-income children and their parents in order to inform ways in which social safety net programs can better serve families living in poverty. The study will consist of a series of semistructured interviews with 30 families in three states. Each interview unit will be made up of one to two parents/guardians and one or two children, yielding a total sample of approximately 45 adults and approximately 50 children (about 20 adolescents between the ages of 12 and 17 and 30 children between the ages of 7 and 11). A Certificate of Confidentiality is needed because sensitive information will be collected during the course of the study. The certificate will help researchers avoid involuntary disclosure that could expose subjects or their families to adverse economic, legal, psychological and social consequences. All data containing PII will be stored on MDRC infrastructure. MDRC protects the systems with anti-virus and anti-phishing software. Confidential, personal, or sensitive data will be encrypted at rest on MDRC’s server. In addition, it is MDRC policy to encrypt data at rest on laptops that are used to collect confidential, personal, or sensitive data onsite. MDRC’s Data Center in the New York City office requires an authorized swipe card for access. All information that could identify research participants will be protected. It will only be seen by researchers when they need it. Both MDRC staff and subcontractors require all staff to sign a Confidentiality Pledge to abide by the corporate policies on data security and confidentiality. This agreement affirms each individual’s understanding of the importance of maintaining data security and confidentiality, and abiding by the management and technical procedures that implement these policies. This research begins on 09/30/2016 , and is expected to end on 07/30/2019. As provided in section 301 (d) of the Public Health Service Act 42 U.S.C. 241(d): "Persons so authorized to protect the privacy of such individuals may not be compelled in any Federal, State, or local civil, criminal, administrative, legislative, or other proceedings to identify such individuals." This Certificate does not protect you from being compelled to make disclosures that: (1) have been consented to in writing by the research subject or the subject’s legally authorized representative; (2) are required by the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 301 et seq.) or regulations issued under that Act; or (3) have been requested from a research project funded by NIH or DHHS by authorized representatives of those agencies for the purpose of audit or program review. This Certificate does not represent an endorsement of the research project by the Department of Health and Human Services. This Certificate is now in effect and will expire on 07/30/2019. The protection afforded by this Confidentiality Certificate is permanent with respect to any individual who participates as a research subject (i.e., about whom the investigator maintains identifying information) during the time the Certificate is in effect. Sincerely, Signed Date: 6/12/2018 Della Hann Ph.D. Associate Director for Extramural Research Eunice Kennedy Shriver National Institute of Child Health and Human Development
| File Type | application/pdf |
| File Title | Dear Dr |
| Author | loomisb |
| File Modified | 2018-07-18 |
| File Created | 2018-06-12 |