Barbara Bierer, "Clinical Trial Data Sharing"

Clinical Trial Data Sharing
Barbara E. Bierer, MD
Professor of Medicine, Harvard Medical School
Faculty Co-Director, the Multi-Regional Clinical Trials Center of Brigham and Women's Hospital and Harvard
Program Director of the Regulatory Foundations, Law and Ethics Program Harvard Catalyst | the Harvard
Clinical and Translational Science Center
January 23, 2017
Health Law Year in P/Review
Petrie-Flom Center Harvard Law School

Disclaimer:
• The opinions contained herein are those of the authors and are
not intended to represent the position of Brigham and Women's
Hospital or Harvard University.
• The MRCT Center is supported by voluntary contributions from
foundations, corporations, international organizations, academic
institutions and government entities (see www.MRCTCenter.org)
and well as by grants.
• We are committed to autonomy in our research and to
transparency in our relationships. The MRCT Center—and its
directors—retain responsibility and final control of the content of
any products, results and deliverables.
1/23/17 2©MRCT Center

Changes in the Data Sharing Culture
1/23/17 3
https://figshare.com/blog/2015_The_year_of_open_data_mandates/143
• Transparency mandates
for research data in
publically funded
programs
• Archiving mandates in
2015: 12 UK, 10 North
America, 5 Europe
• Coinciding with:
– The rise in ’big data’
– Awareness of re-
identification risks that
come with big data and
data combination
©MRCT Center

Goodbye Obama
“22 Federal departments and agencies accounting for more than 99% of
U.S. Federal R&D expenditures now have public access plans in place."
1/23/17 4
NIH Plans: https://grants.nih.gov/grants/NIH-Public-Access-Plan.pdf
©MRCT Center

Scope of Personal Data
Any information:
• Relating to a natural, living person
• Who can be identified, directly or indirectly, in particular
by reference to an identifier such as:
– a name
– an identification number
– location data
– online identifier, or
– one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that
person.
©MRCT Center 51/23/17

US Government funders
Data Sharing Plan
requirements:
Institutions, Foundations, NSF,
DOD, DOE etc. as a condition of
review of application
18 agency specific policies
>65 Repositories
Required data deposit
1/23/17 ©MRCT Center 6

Clinical Trials Registries

Publishing Clinical Reports
81/23/17 ©MRCT Center

EU Transparency legal requirements: Clinical Trials Regulation
• Article 81(4) of Regulation (EU) No. 536/2014
– EU database publically accessible by default, irrespective of the
Marketing Authorisation Procedure (national, central, mutual
recognition, decentralised), with exceptions justified on any of the
following grounds:
• Protection of personal data;
• Protection of commercially confidential information (in particular
taking into account the manufacturing and technical specifics of
the medicinal product, unless there is an overriding public
interest in disclosure);
• Protecting confidential communication between manufacturers
and EMA in relation to the preparation of the assessment report;
• Ensuring effective supervision of the conduct of a clinical trial.

EU Transparency legal requirements: Clinical Trials Regulation
Article 81(4) of Regulation (EU) No. 536/2014
Results of trials are proposed to be made public:
• 12 months after the end of the trial – summary results and layperson summary
• 30 days after the decision on marketing authorization or its withdrawal by the
applicant – the clinical study report of trials authorized under this Regulation
and included in a EU marketing authorization application (central or national)
• Timing of release of details of phase I trials may be deferred until 12 months
after the trial (and published with the summary results)
• Protocols, subject information sheets, IMPDs and investigator brochures, may
be deferred differentially dependent on the nature of the IMP and of the trial.
“End of trial” is defined in Article 2(26) ‘End of a clinical trial’ as the last
visit of the last subject, or at a later point in time as defined in the protocol.

EU Policy 70: Clinical Report Publishing
• Commercially confidential information (CCI) EMA position: majority of clinical
report content is not CCI
• Redaction principles set out in the policy
• Two sets of data prepared: (1) scientific review and (2) publication
• Justification table required: company justifies each redaction, EMA reviews
redactions & decides if accepted or not
Anonymisation
Data utility: important for researchers, EMA encourages utmost data
utility, balance to protect personal data, EMA guidance recommends
methodology to avoid (re)identification of clinical trial participants,
various techniques, evolving area.

Journals
Proposal:
• A plan for data sharing as a component of clinical trial registration
• Sharing deidentified IPD required, 6 months following publication

White House & USG Proponents
The White House Office of Science and Technology Policy (OSTP) issued a Memorandum on Feb. 22,
2013 entitled Increasing Access to the Results of Federally Funded Research directing each Federal
agency that conducts over $100 million annually in research and development expenditures to
develop a plan to support increased public access to the results of that research. In response to the
OSTP Memorandum, the NOAA Research Council issued the NOAA Plan for Increasing Public Access
to Research Results (PARR) in February 2015. Among other requirements, the NOAA PARR Plan
instructs the NOAA Environmental Data Management Committee (EDMC) to revise its existing NOAA
Data Sharing Policy for Grants and Cooperative Agreements; this document (version 3.0) is the
revised directive and supersedes the previous version (2.0). "Data sharing" means making data
publicly visible and accessible in a timely manner at no cost (or no more than the cost of
reproduction), in a format which is machine-readable and based on open standards, along with
metadata necessary to find and properly use the data.

IOM
• Funders and Sponsors should require data sharing
and provide appropriate support
• Journals should require sharing of analytic data set
supporting the published results of a trial
• Universities should require data sharing and
consider in promotion
• Research ethics committees
• Regulatory agencies
Recommendation 1:
Create culture in which data sharing expected norm

Specifics are important: “deidentified IPD”
1/23/17 15
• Anonymization:
– Information which does not relate to an identified or identifiable natural person
– Data rendered anonymous in such a way that the data subject is not, or no longer,
identifiable
• Pseudonymization:
Processing of personal data in such a way
– that the data can no longer be attributed to a specific data subject
– without the use of additional information
– as long as that information is kept separately and subject to technical and
organisational measures
– to ensure non-attribution to an identified or identifiable person
• Deidentification
– code may be maintained
©MRCT Center

Goal of Mandates and Policies: Utility of Research Data
• Leverage existing data for new scientific questions
• Combine from across:
– Disease
– Regions
– Data generators

Rise in Data Repositories and Sharing Platforms
• New options for publishing data are being created
• Not all designed for secondary use or analysis
• Not all designed or capable of holding IPD data
• Multiplicity of repositories may challenge objective

Major Clinical Trials Data Sharing Platforms
1/23/17 18
• CSDR - leading industry multi-sponsor request site
• Clinicaltrials.gov – searchable database including summary results, not IPD
• YODA project - Yale partners with J&J /Medtronic
• Duke Clinical Research Institute – Bristol Myers Squibb Strategic Initiative
(SOAR), which supports open access to clinical trials data
• Project Datasphere – Cancer comparator data, and more
• NIH data repositories and (BIOLINCC and 60+ others)
• FDA Oncology’s data aggregation effort - Information Exchange and Data
Transformation (INFORMED).
• OPENTRIALS – indexes all freely available information, no IPD
• EMA Database – CSRs submitted to the agency as part of a MAA
Currently not interoperable nor are most of these systems integrated
©MRCT Center

Current Gap
We and others have identified significant current challenges to
utilizing existing data on clinical trials for further research:
• Many academicians and others do not have a means to make data
available in a turn-key fashion.
• Although technology has made it easier to make data available,
data are still difficult to discover.
• A robust centralized search engine does not exist to locate data
across the different data generators and data platforms.
• Combing datasets from different generators is resource- and time-
intensive due to inconsistent adoption of data standards, data
requirements, security standards and policies.

1) Enabling interoperability of data
from multiple sources;
2) Hosting data for stakeholders
that do not have the ability to do
so;
3) Coordinating and partnering with
existing data-sharing initiatives,
policies, and processes as
appropriate;
4) Promoting reasoned solutions to
challenges of data sharing.
20
Scope

The Unique Remit of Vivli – Enhancing Discovery
Advanced metadata search and discovery capability
Simplified access request system to data residing on other platforms
1/23/17 21
Searching multiple
databases in a
fragmented landscape
Discovery of data can
be challenging
More communities and
partners = more
discoverable data
As the enhanced metadata catalog matures, more data, including externally hosted
data, will be discoverable through Vivli
©MRCT Center

Vivli Solutions Offerings
1/25/2017
22
Vivli Search and Request Tool
VivliYodaCSDR
GSK Lilly Takeda
Roche
Etc.
JnJ Medtronic Vivli
More
Other
IRP IRP IRP IRP
Open Search User Request Approved Request
Secure
analytic
Environment
Dr. X
Data
Vivli
Yoda
GSK
Centralized search
and request portal
for data hosted on
multiple platforms
Enhanced
Metadata for
more precise
search results
Secure space to
combine IPD data from
multiple sources,
including upload of
academic data
Hosting for clinical trial data,
including minting DOI for
publication purposes
Respecting other
contributor review
processes and data use
terms while providing
user with centralized
mechanism for request
Examples of existing platforms

Why Vivli is Needed
• Data hosting capacity
– Vivli is a general access data platform that flexibly designed to meet global
capacity needs
• Analytic functionality / value
– current federated architectures (e.g., SENTINEL, PCORnet) offer only limited
analytic capabilities (e.g., counts)
– To enable meta-analysis and other aggregated analyses, datasets need to
be held in a single host environment
– The greater the proportion of IPD datasets held by one host, the greater
the ability to do aggregated analyses
– Scale and scope of IPD hosting

Data Sharing: “Data Author” Designation
1/23/17 24
• Responsible for integrity and curation of data
• Data consistent with FAIR principles
• Listed on the primary publication
• Cited in Medline
• Searchable through NLM (and other search engines)
• Reflected on CV
• Utilized for promotions, tenure decisions, funding decisions
• Metrics to be developed over time
©MRCT Center

Closing Remarks
• Clinical trial data sharing, including sharing (deidentified)
IPD, is rapidly becoming a reality
– In 2017: anticipate final ICMJE policy
• Forward progress in sharing aggregate research results
directly with participants (and public)
– In 2017: anticipate final EMA policy with requirements to post
summary results
– Anticipate US FDA will not require sharing summary results
• Progress in sharing individual research results
– In 2017: anticipate further guidance, no requirements

Discussion
&
Thank you

Barbara Bierer, "Clinical Trial Data Sharing"

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