MCHP Data Access Process - Step 5 - Privacy, Ethics & Data Provider Approvals / Permissions
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Overview

Every research project must obtain approvals / permissions from the appropriate data providers / organizations before the research project can begin. The type and number of approvals / permissions required depends on who is doing the research, the type of data the project is planning to use, and the scope of the research being proposed.

  • Every research project must obtain approval from the Manitoba Health, Seniors and Active Living (MHSAL) Health Information Privacy Committee (HIPC), and the University of Manitoba Health Research Ethics Board (HREB). The Principal Investigator (PI) is responsible for submitting and obtaining approvals from HIPC and HREB.
  • Additional approvals / permissions are required if you are using data from non-Manitoba Health, Seniors and Active Living (non-MHSAL) Data Providers, or data / analyses that directly or indirectly identify First Nations, Metis, and/or Inuit populations. The MCHP Repository Access Unit (RAU) will assist you in submitting the appropriate documentation for approvals/permissions.
  • All approval submissions must identify the same PI, project title and data request table. Failure to do so may result in delays to your project.
  • For graduate students, you must have your research project approved by your committee prior to submitting any other approvals. Graduate students are expected to obtain your own set of approvals for your research project. For residents and undergrad students planning a project under an existing research project, no additional approvals are required. However, the existing research plan / proposal must be amended to include the student as part of the project personnel. For more information, see the MCHP Guidelines for Student Use document.
  • Please DO NOT MAKE Amendments during the initial proposal and approval process. This will only result in delays to the approval process. 

Approvals / Permissions Required

The approvals / permissions required include:

    1. Health Information Privacy Committee (HIPC)

    • See the HIPC Submission Information web site for current information about the HIPC submission process including:  a list of Submission Requirements, instructions and guidelines for completing a HIPC application, the HIPC Application form, when the next scheduled HIPC meeting is being held, and where to send the HIPC submission.
    • HIPC Application Form - Annotated Example - pdfNote: This example may use an outdated Application form and is for guideline / illustration purposes only.

    2. University of Manitoba, Health Research Ethics Board (HREB) Requirements

    • HREB approvals can be obtained by all U of M employees, students, academic appointments and researchers affiliated with the WRHA. Submissions to HREB must include a U of M or WRHA associated researcher.
    • See the Office of Ethics and Compliance - Submission Requirements web page for current information on the HREB submission process, including:  guidelines, submission deadline dates, common REB submission pitfalls documentation, and a link to the submission form.
    • HREB Application Form - Annotated Example - pdfNote: This example may use an outdated Application form and is for guideline / illustration purposes only.

    NOTE: Please check for updates to the HIPC and HREB requirements before submitting your application as the information / process changes periodically.

    Additional Notes:

    • The nature of most research using the MCHP Data Repository requires completion of the HREB Submission Form for Retrospective Chart or Records Review.
    • Obtaining approvals from HIPC and HREB is the responsibility of the Principal Investigator (PI) or project coordinator.
    • HIPC, HREB, and other approval submissions may be submitted at the same time, but processing time may vary depending upon approval committee meeting schedules.
    • Your project may be subject to review by the University of Manitoba Research Quality Management Office.
    • Non-U of M researchers and external researchers may require confirmation from other ethics boards that the proposed research project meets the required ethical standards.

Depending on the scope of your research project, additional approvals/permissions may be required from:

    3. Non-MHSAL Data Providers (if applicable)

    • If your project requires access to data from non-MHSAL data providers (e.g. WRHA,  Education, Family Services, Justice) you must submit additional approval requests for use of the data and receive approvals from these agencies.
    • The required approval agencies will be identified in the "quotation" letter from the MCHP Associate Director of Research Access and Use.
    • The MCHP Repository Access Unit (RAU) will provide you with the necessary templates or processes for requesting approvals from non-MHSAL data providers after you confirm that you have acquired funding for your project - please do not use templates from prior submissions as these processes may have changed.

    4. First Nations, Metis, and/or Inuit Representatives (if applicable)

    • MCHP is committed to partnership and collaboration when working on research projects that directly or indirectly identify First Nations, Metis, and/or Inuit populations as part of the research carried out using the Manitoba Population Research Data Repository. We have made a commitment when using data that directly identifies Indigenous populations, or a primary outcome could be attributed to an Indigenous population, that partnership and collaboration will be sought from the appropriate individuals, communities, or representative groups. MCHP is committed to research following First Nations/Metis/Inuit ethical standards.
    • Partnership and collaboration will be sought when:
      • First Nation, Metis, or Inuit individuals or communities will be identified specifically - this includes research that specifically looks at whether a participant is First Nations, Metis, or Inuit (e.g. use of the Manitoba First Nations Research File or Metis Registry, or use of a field that identifies participants belonging to a specific First Nations, Metis, or Inuit group) and the research results use First Nations, Metis, or Inuit community membership as a specific variable, or the interpretation of the results refer to First Nations, Metis or Inuit people, language or culture. This would include the use of data that is collected through specific authorities or groups that represent Indigenous populations (e.g. Child and Family Services (CFS) authorities) and the primary outcome is associated with those populations.
      • There is a risk of attribution or stigmatization toward First Nations, Metis or Inuit individuals or communities - this includes situations where there is an over representation of First Nations, Metis, or Inuit individuals in the study cohort or population. MCHP understands that a risk for attribution may not be evident when starting out on a research project; if this changes during the project then input and advice will be sought before continuing with the research.
    • The MCHP Repository Access Unit will provide you with the appropriate contact information for requesting approvals / permissions from First Nation, Metis and/or Inuit representatives after you confirm that you have acquired funding for your project.

    5. Project Specific Data Approvals (if applicable)

Private Sector / Industry-Sponsored Research Projects

  • For private sector / industry-sponsored research projects being done by MCHP, MCHP will assist in facilitating approvals from HIPC, HREB, non-MHSAL data providers, First Nations, Metis, and/or Inuit representatives.
  • Please contact private_sector@cpe.umanitoba.ca for assistance.

Tasks

The required tasks include:

  • Complete HIPC Application form.
  • Complete HREB Application form.
  • Complete non-MHSAL Data Provider approval forms (if applicable). MCHP will provide you with the current templates for obtaining approvals from each of the non-MHSAL data providers. Please complete the templates and return them to MCHP who will facilitate the submission of these forms and any required supporting documentation to the appropriate organizations.
  • For project specific data, the Data Sharing Agreement or letter of approval is sufficient. (if applicable).
  • Forward copies of ALL the completed documentation to MCHP.  This includes: approval/permission application forms, subsequent approvals, and any additional supporting documentation.
  • MCHP will Submit Documentation for Final Approval from HIPC - once all the required approval/permission documentation is received at MCHP from all organizations involved, this documentation will be submitted to HIPC, by MCHP, for review and to obtain the final HIPC approval for the research project. 
  • HIPC Final Approval Notification - HIPC will notify the researcher and MCHP when they provide final approval for the research project.

    Additional Tasks for Students

    • Graduate students must have their research project approved by their committee prior to submitting any other approvals. For more information, see the MCHP Guidelines for Student Use document.

More Information

Next Step

The next step in the MCHP Data Access Process is Step 6 - MCHP Researcher Agreement and Approval Documentation Submission.


Page Last Updated:  July 6, 2020