OUSD(P&R) Human Research Protection Program (HRPP)
Using or Collecting Data from DoD/P&R Sources
The Office of the Under Secretary of Defense, Personnel and Readiness (OUSD/P&R) house’s much of the Department of Defense’s personnel and health data, therefore OUSD/P&R receives many requests, internal and external, for data from these DoD systems of records. In addition, OUSD/P&R reviews DoD-wide or multi-component survey or data collection activities such as surveys, interviews, and focus groups.
For more information on:
Types of DoD Data:
For research purposes, there are two types of individual level DoD data: identifiable data and non-identifiable data. Data are considered identifiable if it contains either direct or indirect identifiers.
Direct identifiers, as the name implies, are those data which provide a direct link to the individuals whose data are in the system of records.
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EXAMPLES OF DIRECT IDENTIFIERS
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Name
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Address
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Phone Number
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Email address & URLs
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Dates directly related to an individual: birth date, hospital admission date
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Numbers directly related to an individual: SSN, License number, ID number
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Other numbers: Medical record number, account number, employee ID
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Biometric identifiers: finger and voice prints
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For health records, the Health Insurance Portability and Accountability Act (HIPAA) included a considered identifiable.
Indirect identifiers are demographic information that alone do not permit individual identification; however, when combined with other demographic information may lead to direct identification. The likelihood of individuals being identifiable increases with each of the following: specificity and extensiveness of the demographics (e.g., exact age vs. age range); small cell sizes, specific geographic region. For example, each of the following might lead to individual identification:
- High income, low age, specific geographic region
- High rank, female gender, military Service
- Ethnicity, specific location (Eskimo in Illinois)
Requesting DoD Data:
If you are requesting data from the DoD, the requirements vary depending on whether the data are . The following chart shows the requirements for each. Click in each box for a detailed explanation.
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REQUIREMENT
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IDENTIFIABLE DATA
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NON-IDENTIFIABLE DATA
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X
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X
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X
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X
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X
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X
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*
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X
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X
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Requirement Explanation for Requesting DoD Data:
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REQUIREMENT
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DESCRIPTION
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Sponsor
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- If the Principal Investigator (PI) is external to the DoD, the PI must have a DoD sponsor (office or appropriate individual) who affirms that the research is in the interest of the DoD.
- If the PI is within one of the services and seeking DoD-wide or multi-component data, the PI may need to have an OSD sponsor.
- The best sponsor is one who understands the data systems.
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Relationship
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The Privacy Act restricts disclosure of personal information from federal systems of records to:
- Officers and employees of the agency who need the record to perform duties;
- Contractors, subcontractors, grantees, and others with whom the DoD has a business relationship;
- Recipients who assure the agency that the record will be used for statistical research or reporting and the data in the record are not readily identifiable;
- Routine use to an outside agency (notice in Federal Register)
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Data Use Agreement (DUA)
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- Describes the specific purpose and use of the data;
- Delineates the individuals who are granted access to the data;
- When data is extracted, DUA specifies how the data will be stored and if, when and how it will be destroyed.
- When data is accessed, DUA process verifies appropriate clearances.
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Privacy Review
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- Conducted by the Privacy Office/Officer for the agency which owns or controls access to the data you are seeking.
- Review elements:
- * Data availability (based on your description), - Minimum necessary data to accomplish research purposes, - * Project feasibility and cost to the agency, - Compliance with Privacy Act, HIPAA and Information Management requirements.
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Human Research Protection Program (HRPP) Review
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- Primary Review conducted by your Institutional Review Board (IRB).
- Secondary Review or Administrative Review conducted by OUSD(P&R) HSPP program officers.
- Review elements:
- Appropriate and sound use of the data, - Compliance with human subject requirements.
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Human Research Protection Program (HRPP) Training
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- OUSD(P&R) requires that the principal investigator (PI) receive annual training.
- The training is web-based, and there is a special course for data users.
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Information Collections:
Information collection= gathering data or information from individuals, including: surveys, interviews, and focus groups.
DoD-wide or multi-component= soliciting individuals across multiple components or agencies. Single component (e.g. Army, Navy, Air Force) information collections are managed internally.
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REQUIREMENT
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PI INTERNAL
(include contractors)
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PI EXTERNAL
(include grantees)
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X
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X
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X
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X
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X
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X
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X
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X
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Requirement Explanation for Information Collections:
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REQUIREMENT
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DESCRIPTION
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Defense Manpower Data Center (DMDC) Review
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- DMDC reviews information collections in preparation for Report Control Symbol (RCS) license.
- Review elements:
- Scientific merit (sampling, design, federal standards) - Minimize burden - Privacy and confidentiality
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Report Control Symbol (RCS) License
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- If the office requesting the information is imposing the requirement on one or more components other than their own, then the requiring office shall obtain a Report Control Symbol (RCS) from Washington Headquarters Service.
- Review elements: Cost, effort, complexity of the information requirement.
- Prior approval from HRPP and recommendation from DMDC.
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Office of Management and Budget (OMB) License
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- If the office requesting the information seeks information from members of the general public, then the information collection needs OMB approval under the Paperwork Reduction Act (PRA).
- Review elements:
- Merit - Burden on the public - Federal Guidelines
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