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									Data Security Protocol




                         1
Why is data security important?
• Compliance with Institutional Review Board (IRB)
  guidelines
   – An IRB is a group designated by an institution to approve, monitor,
     and review research involving human subjects to assure appropriate
     steps are taken to protect the rights and welfare of those subjects. It
     is a federally registered body.
   – Non-compliance can jeopardize:
       • Funding
       • Research progress
       • Organization’s reputation
   – This protocol aims to follow Harvard’s guidelines for security of
     personally identifiable data in research
     http://www.security.harvard.edu/research-data-security-policy
• Protection of human subjects
   – Field projects often collect personally identifiable
     information (PII) from respondents
   – PII + other sensitive information (e.g., financial or medical
     data) = RISK
Overall principles for data security
1.   Use Cold-room computers, passwords and encryption: PII
     should only be viewed on cold-room computers that are
     password-protected and are equipped with TrueCrypt

2.   Pick strong passwords for files and computers. Rule of
     thumb: more than 10 characters, alpha, numeric, caps and non-
     caps, and symbols should be included (all). No dictionary words.
     Share verbally and keep record of passwords in a secure
     location.
3.   Ensure physical security: Keep data in a physically secure
     location
4.   Store, transmit, and use PII separately as much as
     possible: Separate personally identifiable information from the
     dataset as soon as possible (while maintaining respondent id
     link). Store and transmit PII separately from rest of data and
     use only de-identified data for analysis as much as possible.
5.   Obtain confidentiality agreements: Confidentiality
     agreements should be signed and kept on record for anyone
     who handles PII (surveyors, data entry operations, project staff)
 Data security for new projects: Stage
 0
                                    Stage 2:
   Stage 0:        Stage 1:                       Stage 3:     Stage 4:    Stage 5:
                                  Secure data
 Before data   Data protection                  Environment     Field       Making
                                  storage and
  collection     in the field                   for analysis   wrap-up    data public
                                 transmission




All Research Assistants/Associates and anyone else who will
have access to data with PII should:

•Take the course (Citi or NIH) on human subjects research
and send the certificate of completion to your IRB coordinator
•Read JPAL/IPA human subjects manual and Data security
checklist
•Read the IRB requirements for the project
•Protect data on computers:
    • Use cold room computer with Password protection and
      TrueCrypt
    • Use secure file transfer and encryption for sending PII
    Data security for new projects: Stage
    1a
      Stage 0:        Stage 1:         Stage 2:      Stage 3:     Stage 4:     Stage 5:
    Before data   Data protection    Secure data   Environment     Field        Making
     collection     in the field    transmission   for analysis   wrap-up     data public
                                                          PII and
                                                                             Rest of
                                                          Consent
                                                                             survey
                                                         Unique ID
                                                         Unique
oStructure the physical survey packet into the “PII-Consent ID
section” and the “Questionnaire section”, so they can be separated

oEnsure that you have a field for the Unique ID Code on every page
of the survey packet. It is CRITICAL that each page of the survey
has the CORRECT unique ID code so that you can match up the
questionnaire to PII if it is necessary later

o Ensure you have a secure location to keep hard copies of
surveys, with the identifying information separate from the rest of
the survey
 Data security for new projects: Stage
 1b
                                    Stage 2:
   Stage 0:        Stage 1:                       Stage 3:     Stage 4:    Stage 5:
                                  Secure data
 Before data   Data protection                  Environment     Field       Making
                                  storage and
  collection     in the field                   for analysis   wrap-up    data public
                                 transmission

                                                    PII                          Survey



•Paper surveys received from surveyors should be physically
separated into PII-Consent section and the rest of the
questionnaire. These two sections should be stored and transported
separately
•Ensure that data entry operators have signed a Confidentiality
Agreement
•Once data has been double-entered, receive datasets on disc
(NOT email). PII and rest of data should be stored in separate discs.
•Confirm that data entry operators have removed the data from
their computers
 Data security for new projects: Stage
 2
                                    Stage 2:
   Stage 0:        Stage 1:                       Stage 3:     Stage 4:    Stage 5:
                                  Secure data
 Before data   Data protection                  Environment     Field       Making
                                  storage and
  collection     in the field                   for analysis   wrap-up    data public
                                 transmission




oTransfer data from data entry to disc to password protected
cold room computer and encrypt immediately
oMake 3-5 encrypted copies of the original data and store on
at least 2 secured servers or computers
o Send encrypted data through a secure file transfer protocol
(SFTP) such as Accellion (HKS) or WinSCP (NBER)
o Sending data containing PII over email or Dropbox needs to
be avoided
  Data security for new projects: Stage
  3
                                     Stage 2:
   Stage 0:         Stage 1:                         Stage 3:        Stage 4:    Stage 5:
                                   Secure data
 Before data    Data protection                    Environment        Field       Making
                                   storage and
  collection      in the field                     for analysis      wrap-up    data public
                                  transmission




      Data analysis does NOT require PII
                       Data analysis does NOT require PII
  (e.g. no need for names, addresses, etc in
                      (e.g.
                   analysis)no need for names, addresses, etc in analysis)
• Maintain two separate datasets: first which contains PII and the
unique id code and a second which contains the unique id code and
the rest of the data (make sure both contain the respondent id code)
• Keep the dataset containing personally identifiable information
encrypted
•Decrypt and download only the second dataset (the one without
personally identifiable information) for cleaning and analysis onto
your computer
•If you need to view the PII, then you should use a cold room
 Data security for new projects: Stage
 3
                                   Stage 2:
  Stage 0:        Stage 1:                       Stage 3:     Stage 4:    Stage 5:
                                 Secure data
Before data   Data protection                  Environment     Field       Making
                                 storage and
 collection     in the field                   for analysis   wrap-up    data public
                                transmission




                   Data analysis DOES require PII
• Download the encrypted file onto a password-protected USB key
or other storage device. Transfer the file in encrypted form to a
password-protected cold room computer

• As long as the data you are working with directly uses PII, you
will need to work on a cold-room computer that is password-
protected. You may not transfer the data containing PII to other
computers.

•There may be ways to de-identify the data and retain the elements
needed for analysis, giving you more flexibility on where you clean
 Data security for new projects: Stage
 4
                                    Stage 2:
   Stage 0:        Stage 1:                       Stage 3:     Stage 4:    Stage 5:
                                  Secure data
 Before data   Data protection                  Environment     Field       Making
                                  storage and
  collection     in the field                   for analysis   wrap-up    data public
                                 transmission




• Once data analysis is finished, hardcopies of surveys need to be
destroyed in a secure manner (e.g., shredded) within 5 years of
completion of the study

•Once all data is received for cleaning and analysis and secure
back-up of the files has been confirmed, completely delete the file
from any field computers (make sure all data has been transmitted
from the field before deleting files)

• You may consider ‘wiping’ your hard drive of these files using a
program such as Eraser (http://eraser.heidi.ie/)
 Data security for new projects: Stage
 5
                                    Stage 2:
   Stage 0:        Stage 1:                       Stage 3:     Stage 4:    Stage 5:
                                  Secure data
 Before data   Data protection                  Environment     Field       Making
                                    storage
  collection     in the field                   for analysis   wrap-up    data public
                                 transmission




• Multiple team members need to review the dataset before it is
released publicly, preferably ones who are familiar with the survey
instruments and data collection

•The potential negative repercussions of making on mistake and
releasing PII on a public database can be huge (imagine leaving a
social security number in a public medical procedures database)

•Always get PI approval before making data public
Data security for existing projects
People:
                                          Digital data:
Ensure requirements are met for all
                                          Take inventory of all digital data in the
team members who have access to PII:
                                          project. For the files that contain PII:
    • Read IRB requirements for the
    project
                                               •Separate PII from non-PII data
    • Certification of completion for the
                                               •Encrypt datasets with PII
    IRB training course is on file
                                               •Assess if PII is needed for
    • Protect data on computers with
                                               analysis and if so, use cold room
    passwords
                                               computer
    •Sign Confidentiality agreements

Hardcopies
    • Ensure that hardcopies are stored
    in an appropriate and secure place.   Scans
    • Once analysis is finished, check    •Scans of hardcopy surveys should
    with PI to get permission to          follow the same protocol as Digital Data
    destroy hardcopies (within 5 years)
    • Using a commercial shredding        •Scan first page separately from the
    machine or giving the hardcopies      rest of the survey
    to a reputable office services
    company
       Sample Confidentiality Agreement
As a member of the research team for the Center for Microfinance
(CMF),I understand that I may have access to confidential
information about individuals participating in surveys conducted by
CMF or partner banks, NGOs and institutions. By signing this
statement, I am indicating my understanding of my responsibilities to
maintain confidentiality and agree to the following:

I understand that all information about study participants obtained or
accessed by me in the course of my work is confidential. I agree not
to divulge, publish, or otherwise make known to unauthorized
persons or to the public any information obtained in the course of
data collection or data processing that could identify the persons
who participated in the study, unless specifically authorized to do so
by office protocol or by a supervisor acting in response to applicable
law or court order, or public health or clinical need.
        Sample Confidentiality Agreement
I understand that I am not to read information or records concerning
study participants, or any other confidential documents, nor ask
questions of study participants for my own personal information but
only to the extent and for the purpose of performing my assigned
duties as a staff member, volunteer or employee of CMF.
I agree to notify my supervisor immediately should I become aware of
an actual breach of confidentiality or a situation which could potentially
result in a breach, whether this be on my part or on the part of
another person.
I agree to return all data in my possession to my supervisor upon
terminating work with CMF or upon being requested by a supervisor
to do so and I understand that failure to do so may result in legal
action.
I understand that a breach of confidentiality may be grounds for
disciplinary action, and may include termination of employment.
Name:                  ________________________
Signature:             ________________________
True Crypt walk-through
True Crypt = Box created on your computer used to hide
(encrypt) files

You can:
• Send these “boxes” like a normal file
• Disguise them to look like something else
• You have to go through True Crypt to both put things inside
the box (encrypt) and take things out (de-encrypt)
                                           Cold room
                                            computer
Encryption and un-encryption in ideal      Networked
world                                       computer
                                             Password-
                                           Protected USB
                                           Encrypted
               PII                         Un-encrypted
                                SFTP
 Does not                                PII stays
need PII in                             encrypted
 analysis

                                        Rest of data
                                        unencrypte
                                             d
              Rest of data
                                                Unencryp
               PII                                  t
                             SFTP
 Needs PII                                         PII
in analysis




              Rest of data                      Unencrypt
                                               Rest of data
   Data Security Checklist
All project staff have take IRB course and sent certifications
Survey structured with PII-Consent detachable from Main
Questionnaire
Field staff sign a confidentiality agreement before working with
data/surveys
Using IRB approved consent form
Unique ID code written on every page
PII-Consent separated from Main Questionnaire prior to data entry
Hard copies stored in a secure location
Only using cold room computer for management and analysis of PII
data
Make 3-5 backup copies (encrypted) of the original data
Transfer encrypted files using file transfer system
Store backup copies on a secured server
Confirm data entry operators have removed data from their

								
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