Use of Research Data after Leaving UI

The University takes the position that it owns any research data collected by faculty, staff or students. Any work (e.g., analysis, manuscript preparation) using identifiable data needs to be done under IRB approval – whether at Iowa or another institution.

Identifiable Private Information.  This is defined as private information about behavior that occurs in a context in which an individual can reasonably expect that no observation or recording is taking place, and information which has been provided for specific purposes by an individual and which the individual can reasonably expect will not be made public (for example, a medical record). This information is considered individually identifiable if the identity of the subject is or may readily be ascertained by the investigator or associated with the information.

(If information includes Protected Health Information (as defined later under Protected Health Information), identifiable information includes any of the following information for the individual, relative, employer, or household member of the individual:

• Name, street address, city, county, precinct, zip code, geocodes smaller than state
• Date of birth, ages > 89 years of age; or other dates such as diagnosis dates, procedure dates, admission or discharge dates
• Telephone numbers, fax numbers, e-mail addresses, social security numbers, medical record number
• Health plan beneficiary numbers, account numbers, certificate/license numbers
• Vehicle identifiers and serial numbers or license numbers, device identifiers and serial numbers
• Web URLs, Internet Protocol (IP) address numbers, biometric identifiers including finger/voice prints
• Full face photographic images and any comparable images.

This means that if you leave the University and have closed out your HawkIRB project (which you must do upon termination of your connection to Iowa), you will:

1. Leave the hard copy data here (usually with your dissertation chair).  You can take a copy with you.
2. If your data will continue to be associated with identifiers, you must get IRB approval from your new institution (local IRB) to continuing working with the data.

• Often the new institution wants Iowa to give approval for use of this data.  To get that, the individual contacts the relevant department head – in the case of the CON, that would be the Associate Dean for Research – in writing outlining their request to use the data.
• The approval from Iowa will include the condition that IRB approval be in place at the new institution prior to working with the data.

If your data will be de-identified (i.e., if you are able to continue your work with a data set containing only aggregated data and/or data that have no identifiers), you may be able to work with the data at your new institution without formal IRB approval, although it would be wise to review this with the IRB at the new institution.