| ✓ Africa lacks integrated data banks the various
data repositories e.g., HDSS sites, H3Africa and
DHS are not harmonised
18,
42,
51
✓ There is limited oversight and unclear policies
by government institutions and research ethics
committees on data sharing and governance of
databanks
219
.
✓ Ethical, legal and social implications
of secondary data sharing are mostly
unresolved
110,
328,
329
.
✓ Public fear of loss of privacy or confidentiality
breach, data misuse and abuse
56,
58,
59
.
✓ Poor communication on data use leads to
distrust from participants
60,
61
✓ Insecurity, growing cyber-attacks, fear of using
the internet
87–
89,
149
, and dishonesty due to fear
of stigmatisation
83
.
✓ Researchers fear of possible loss of academic
advantage and independence; loss of
intellectual property
70
. | ➢ A need to develop integrated and harmonised databanks and frameworks for data sharing in
Africa
133,
140,
330
. Examples could be drawn from the Australian Population Health Network
65
; the
Canadian National Data Platform
66
; and the UK’s Health Data UK
67
.
➢ Develop policies on regulatory oversight and that enables collaborations
47,
48
.
➢ A need to develop a harmonised agreement that respects the independence of separate
entities while promoting robust and efficient cross-disciplinary research within the confines of
national and international ethical and legal frameworks
68
.
➢ Develop proper governance of databanks, quality management and sustainability
47,
48
.
➢ Data custodians must adhere to ethical guidelines (e.g., privacy, trustworthiness) in data
sharing
83–
85
, and use or share the data for public good and social justice
89,
149,
152,
331
.
➢ A need to improve on communication to research subjects regarding data sharing using
strategies such as modular education approach
90
; use of video
91
, pictures and vignettes
92,
93
.
➢ Need to conduct a public education on data reuse to promote trust and public participation
78
.
➢ A need to collect rich metadata of each data set
80,
81
.
➢ Other considerations are detailed in Wiehe
et al., including identifying data sources/patterns,
engagement with leaderships, ethical and regulatory compliance, etc.
121
. |
| B) DATA PROTECTION LAWS AND GUIDELINES |
|---|
| ✓ Limited to moderate data regulation and
enforcement particularly in Africa
92
.
✓ Other unaddressed issues include public view
or perceptions of cross border data transfer
120
. | ➢ African countries without data protection policies must develop data protection policies by
learning or borrowing from global models such as the UK Data Protection Act of 2018
94
, and
examples from the African continent
92
➢ Develop safe harbour privacy protection principles to address cross border regulatory
bottlenecks, increase data sharing efficiency, and promote data harmonisation
245
. |
|
Ethics
Committees
(EC)
| ✓ lack of legal protection
96
.
✓ Inability to reach quorum in decision making
and inappropriate constitution of ethics
committees (EC)
152,
153
.
✓ Inefficiency or bias amongst its members
99
.
✓ Lack of financial and administrative support to
enable it to function smoothly
332
.
✓ Social implications of data sharing often falls
outside the ECs mandate
50,
100,
101
.
✓ EC members’ poor familiarity with secondary
data use, including laws governing cross-border
transfers may be an impediment to safe data
sharing. | ➢ A need to build capacity of research EC to ensure consistent and efficient application of data
sharing regulations
333
.
➢ EC must be guided by global ethical guidelines including The Helsinki Declaration which
provides guidance on data security, ethical principles and governance of data sharing
102
.
➢ Other guidelines include: the Australian Guidelines on Human Biobanks and Genetic Research
Databases
103
; The OECD Principles and Guidelines for Access to Research Data from Public
Funding
104
; the Bermuda Principles
105
; Fort Lauderdale Agreement
334
among others.
➢ The material transfer agreement (MTA) documents should include issues of data provenance,
data quality assurance, meta-data and other requirements for accurate interpretation of data,
intellectual property, informed consent, security and privacy terms etc.
107,
335
.
➢ Develop Ethics waiver policies including setting up a central adjudicator of request when re-
identification is necessary, and consenting is impractical. Examples include the Confidentiality
Advisory Group (CAG) and the Public Benefit and Privacy Panel (PBPP) in England and Scotland
respectively
54
. |
|
Consenting
| ✓ There are no clear guidelines for conducting
informed consent
336
.
✓ Complex use of data has make it difficult
to differentiate between data collected for
routine medical care and data collected for
research
49,
198–
201,
337
.
✓ Possible risk of patients and research
participants being relegated to data donors,
and negating the principles of autonomy and
self-determination
109
✓ There are unresolved issues on future use of
data, including when participants want to opt
in/out of studies
111
.
✓ The scope of consenting is also not so clear in
longitudinal studies, especially those involving
minor
62
, and parents may be reluctant to
consent for minors. | ➢ It is important to give people the opportunity to negotiate how others use their personal
information
338
.
➢ Researchers/Investigators must ensure that consenting process is a broad, continuous
process and touches on data sharing clauses (data sharing now and, in the future), and ensure
waivers permitting the use of de-identified data
110
.
➢ Longitudinal studies should have follow-up mechanisms e.g. collecting additional identifiers for
participants on the consent form to allow future re-contacting for further consenting
156
.
➢ Research ethics committees should contend with emerging considerations of data stewardship
such as the longer than usual data storage, sharing, re-identification and indeterminate future
use of collected data
26–
30
.
➢ Researchers must ensure that participants have enough information about their studies and
consent options including a consent waiver, dynamic consent to opt in and/or opt out etc.
111
.
➢ There is need to adapt existing software to facilitate data governance and participants’ control
of their data
52,
339,
340
. Examples include Fast Healthcare Interoperability Resources (FHIR), Sync
for Science, Private Access, Patient Health Records (PHR) and Blue Button
133,
239
. |
|
Data ownership
| ✓ Laws and Policies on data ownership are not
clear
133
. For instance, patients have the right
to request and retain their data. Similarly,
clinicians have the right of data retention for
clinical purposes,
✓ This lack of clarity on data ownership and
custodianship is influenced by variations
of what constitutes data – Data range from
numbers to letters, symbols, idea, condition or
situation
341
. | ➢ Data ownership should be governed by legal and moral obligations including trust and
custodianship with variations in the right of access and utility by different stakeholders
133–
135
.
➢ There is a need to adopt a non-exclusive ownership of data – whereby data ownership should
be governed by legal and moral obligations.
➢ Data custodians must adhere to principles of respect for privacy and autonomy; reciprocity
and feedback to stakeholders; acknowledgment and attribution to contributors; and, respect
for intellectual property
107,
311
. |
|
Intellectual
property rights
| ✓ Data sharing may raise several issues to
researchers, employers, and funders on: What
are the legal rights in data? Who has these
rights? And how does one with these rights use
them to share data in a way that permits or
encourages productive downstream uses?
✓ Some data repositories e.g., journals have strict
measures that hinder access to data by those
who cannot pay for it. | ➢ There is need to develop a system and guidelines/templates for Intellectual Property that is
guided by local intellectual property laws
104,
114,
136
.
➢ Databank users are required to report back all publications and patents emanating from the
data provided to them
107,
117,
119
.
➢ Genomic databases are global public good and all humans should share in, and have access
to, the benefits of databases
342
. Similar views are shared in UNESCO’s International Declaration
on Human Genetic Data
343
. Thus, provide access to databases to anyone who rightfully
demonstrates a need to access the data. |
| C) ENABLERS OF DATA SHARING |
|---|
|
Stakeholder
and Community
engagement
| ✓ The concept of Stakeholder/community
engagement is somewhat ambiguous, and
there is lack of clarity of who must be included
in the consultations
344,
345
.
✓ Loss of trust may pose a risk to social licence
315
.
✓ Unresolved situations like the continuous
involvement of patients or study participants
have the potential to weaken public trust and
negates the principles of solidarity
and social justice
109
. | ➢ Stakeholder consultation is an important strategy to promote equity, trust, transparency,
autonomy and participation in data storage/sharing
10,
109,
153
.
➢ Communication should be done with the required sensitivity to avoid ambiguity and
misinterpretation
153
➢ Community engagement should commence at the beginning of the project, to ensure
feasibility and timely risks mitigation with stakeholders’ input
109
.
➢ The consultation should clarify purpose of the data storage and sharing platform, roles
and responsibilities, governance and accountability mechanisms, data protection, types of
informed consent, benefit sharing, intellectual property, and data ownership. Exemplary
framework can be drawn from H3Africa
154
. |
|
Trust
| ✓ Social licence may be misinterpreted as trust,
which may be implied as informed consent to
use information offered for research
137
. | ➢ In the case of big databanks, maintaining trust should be on-going and not a onetime
checkbox activity.
➢ The engagements should also be cross cutting to involve other researchers, policy makers and
funders, and not only research participants and communities
112,
113,
140,
141
. |
|
Respect
for study
participants/
groups
| ✓ Issues may include where researchers do not
disclose fully to participants on future use of
data.
✓ Another issue would be not being clear during
consenting time whether participants will be
recontacted or not. | ➢ Use of data should be in line with the scope of original informed consent provided by the
research participants.
➢ The intention of the research is clearly stated during consenting/at the time of data collection
including likely future use of the data
112,
114
.
➢ In absence of specificities, broad consenting should be done to protect the research
participants
112–
114
.
➢ Elements of respect may include privacy protection and confidentiality; autonomy; data
security; respect for individuals and group rights; ensuring dignity of participants; and,
protection of life, wellbeing and welfare
10,
102,
112,
119
.
➢ Re-contacting participants should of course, follow standard ethical principles including
options on communication of findings or participant access to data
117,
118
. |
|
Transparency
| ✓ Providing patients or study participants with
insufficient information on how data will be
managed or shared
83,
86,
152,
346
.
✓ unspecified secondary use of data
104
.
✓ Giving multiple users access to data
99,
104,
105
.
✓ Data misuse, identity theft and sharing data
on the internet
99,
101,
103,
119,
121
, and centralised
database without sufficient safeguards
99,
119
. | ➢ Researchers must ensure participants are informed about how data will be shared and with
whom
53,
142
.
➢ Researchers must disclose to participants about monitoring policies and database governance,
conditions framing access to data and data access agreements
144–
146
.
➢ Also, disclose the role of patients and human rights advocacy groups involvement in providing
oversight and supervision of the platform to ensure unbiased access and utilization of the
databank
148
.
➢ Ensure proper keeping and communicating sufficient records of operational activities including
audits logs and trails
86,
87,
149
. |
|
Incentivization
of data
contributors
and users
| ✓ funding agreements, collaborative agreements,
data sensitivity, privacy, giving up chance to
publish, public critique, lack of data repositories
and the absence of consent to share
160,
165
.
✓ Fear of exploitation especially amongst
researchers in low resources countries
161
.
✓ Threat to intellectual property, professional
value and economic benefits
166
.
✓ The greater value placed on publications by
institutions may also be discouraging data
sharing
164
. | ➢ It is important for governments and funders to ensure capital and infrastructural development,
and financing to promote research data sharing
165,
167–
169
.
➢ Research institutions and researchers need to promote tangible reward in the form of
reputational incentives and peer recognition including citation to enhance data sharing
158,
170
.
➢ Make data sharing a requirement for project funding, journal publications, university tenue or
promotion
212,
270
.
➢ A need to develop clear data sharing policy that addresses the concerns of all stakeholders,
including monitoring and reward mechanisms
161,
173
.
➢ A need to promote diversity and inclusion of minorities and vulnerable groups
56
and
international partners in data sharing
178
.
➢ Develop open data badges – which is a tested intervention to improve data sharing
171,
179
. |
|
Funders and
researchers’
position
| ✓ Most researchers or scientists in Africa are
hesitant to share their data largely due to lack
of awareness of the benefits of data sharing.
✓ Lack of funding and limited provisions for data
sharing.
✓ Few members of African ethics review boards
are familiar with the concept of data sharing
amongst other ethical issues discussed such as
broad consenting | ➢ We recommend proactive advocacy to ensure that the concept of data sharing becomes a
mainstream consideration in national discussions of research management and governance
70
.
➢ There are policies that illustrate that all data is public good, and all funded research should be
shared. This includes the Wellcome Trust
180
and the USAID’s Policy on Development Data
181
.
➢ A need to train researchers on data management, and the recruitment of dedicated support
staff to document data and manage repositories
155,
221,
253
. |
| D) GOVERNANCE AND VALUE-BASED IMPLEMENTATION |
|---|
|
Policies and
Values
| ✓ Most guidelines and regulations within Africa
do not provide clear guidance on governance
and how data and samples ought to be
shared
182,
183
.
✓ Lack of clear policies on data sharing may
both frustrate researchers who want to share
data and provide loopholes for those who are
unwilling to share.
✓ Diminished confidence on government
custodial of the data
142
. | ➢ Governments and research institutions in Africa must develop clear guidelines on data sharing
and repositories.
➢ Create clear laws to govern re-identification and stronger sanctions and corresponding
enforcement protocol for misuse of data
133,
189,
190
.
➢ Establish proper governance by providing a guideline on who, how, when and under what
authority datasets can be linked or merged
83
.
➢ Develop a central policy and inclusive governance structure that promotes collaboration and
participants
133,
148
. |
|
Data
anonymization
and re-
identification
| ✓ There is also an increase in clinical audit of
patient records for quality improvement
practice and research without individual patient
consent
50,
198–
201
.
✓ Yet, data anonymization may be challenging
when researchers or clinicians want to link
medical data to make clinical decisions in
future, or recontacting patients to obtain
additional information.
✓ Growth of the database means anonymity
will not allow linking datasets or to re-identify
individuals in the database if there is ethical
reasonability and lawful approval to re-identify
the participants
113,
119
. | ➢ Researchers and data custodians must be aware of possible identifiers, which can be direct or
indirect
191,
209
.
➢ Data controllers must uphold to the consent given by patients or study participants, use
of appropriate technologies, mechanisms and permission to promote pragmatic dynamic
consenting processes properly described by Kaye
et al.
216
.
➢ Researchers must ensure that details on data reuse and protective measures are clearly stated
in the informed consent, and inform participants when absolute anonymity is increasingly
impossible to guarantee albeit highly preventable
107,
191,
192
.
➢ It is important to adequately educate researchers and data custodians to ensure data privacy
protection compliance as well as signing renewable confidentiality pledges
153
.
➢ Data should be de-identified before it is shared
310
|
|
Data Access
| ✓ Most data sharing agreements are silent on
the consequences of violating data access agreement
234
and rely on national regulations.
✓ Limited awareness and access to databanks
available for secondary users
219
. | ➢ Develop clear data access agreements or guidelines on what the application can and cannot
do with the data provided
260
as well as consequences of nonadherence to data access
agreement
234
.
➢ Data access should not negate the principles of autonomy, privacy, public interest and benefit,
acknowledgment of data contributors, transparency, accountability and trustworthiness
193
.
➢ Promote data access discussions during stakeholder and collaborative partnerships, including
resource provisions to addressing the impediments to data sharing
220
. |
|
Data access
committees
(DACs)
| ✓ Financial constraints and lack of sufficient
oversight mechanisms
240
.
✓ There is lack of clear definition of the
relationship between DACs and biomedical
research ethics committees (ECs) when
conducting evaluations.
✓ Insufficient oversight mechanisms
59
✓ Inequalities in terms of the composition
of DACs- which may exclude important
stakeholders
242
.
✓ Conflict of interests between DAC members and
other stakeholders
242
. | ➢ DACs must be provided with adequate funding to perform their roles
240
➢ Develop clear guidelines and framework to guide functioning of DACs.
➢ A need to adapt to technological, scientific, data security, new data sources and research
methodological advances and changes in public sentiments
347,
348
.
➢ The need to have an oversight over DAC is recommended
59,
240
.
➢ To address inequalities and curtail vested interests, DACs should be inclusive, global and
transparent
242
.
➢ DACs should be an independent committee without conflicts of interest or measure to
evaluate and mitigate its internal risks
240
. |
| E) DATA INFRASTRUCTURE, QUALITY, STORAGE AND SECURITY |
|---|
|
Infrastructure
| ✓ Many African institutions have limited
infrastructure (spaces, inadequate equipment/
tools, power supply shortages, poor
information technology) for data repositories
and data sharing
1–
3
. | ➢ There is a need to develop ICT infrastructure and efficient workflow; harmonised policies,
guideline and operating procedure; data access policies and mechanism; and, government
regulation and oversight
349
.
➢ Other considerations include human and social capital, financial resources and governance
350
.
➢ Developing an adaptive information technology enabled system.
➢ Ensure adequate financial resources to address the mentioned challenges. |
|
Data Quality
| ✓ Some of the reasons why scientist do not reuse
data include concerns about data quality; lack
of awareness of benefits of big data; and, lack
of technical capacity to use big data
351
.
✓ Scepticism and self-doubt of quality of research
may inhibit some researchers from sharing
their data
178
.
✓ Poor data quality in Africa is due to lack of
infrastructure, inadequate skills and capacity
amongst researchers as well as lack of
guidelines on how data must be prepared
or processed. | ➢ Data custodians and Databanks must establish high quality threshold indicators for routine
review and updating
104,
112,
117,
248
.
➢ Data quality assurance should be documented, unbiased, open to review, factual and
proportionate
10,
104,
117,
119
.
➢ Researchers and data custodians must establish the contextual meaning of data to minimise
misinterpretations. Example can be drawn from the H3Africa model
42
.
➢ It is important to also offer data seal of approval to guarantee researchers that data will be
stored in good quality, and consistent reuse while ensuring the trustworthiness of digital
archives
250,
251
.
➢ Regulatory licencing and oversight of databanks could also help ensure quality and
accountability
252
. |
|
Data storage &
Retrieval
| ✓ Identification of anonymised data, increased
risk of disclosing other data, misinterpretation
of data for various reasons, malicious use
of data, harm to the public posed by illegal
disclosure and commercialization
128,
253
. | ➢ Cataloguing data in a consistent manner will promote harmonization and interoperability
254
.
➢ African data scientists or custodians must draw from internationally accepted norms and
standards to ensure compatibility
104
.
➢ Data custodians (e.g. on online platforms) must ensure: metadata availability, discoverability,
data standardization, quality assurance, storage, backup, migration, succession plan, legal
status, access and terms of use and more shown in the table
161,
255
.
➢ Develop an integrated system such as the Open Archival Information System (OAIS) for data
management and sharing
256,
257
.
➢ Databanks must store anonymised or de-identified data with additional safety and access
control measures
24,
113,
259,
260
; use individual unique identifiers
153
or aggregate datasets
218
. |
|
Security
| ✓ For cloud data- issue of integrity and
exploitation of data by service provider and its
employees
222,
274–
276
, cloud attacks
277
,
✓ User identity spoofing
278
,
✓ Data tampering
279
.
✓ Denial of service
280
.
✓ Unlawful access to database and infiltration of
the system
278
.
✓ Danger of re-identification of de-identified
data
281
. | ➢ The success of data security (including cybersecurity) will depend on good governance that
ensure compliance with safety regulation by all parties.
➢ A need to develop policies on data security that mandate the custodians of data to protect it
from abuse, unauthorised access and tampering, loss or unlawful disclosure
272
.
➢ Privacy protection provide a notification in the event of breach of privacy due to unauthorised
access, loss or disclosure of information in the care of a legal data custodian
273
.
➢ Establishment of remote access controlled data centres, and good monitoring systems
107,
283
. |
|
Sustainability
of databanks
| ✓ Challenges to sustainability include the cost of
maintaining a central databank, issues of social
licence and public distrust and limited oversight
of commercial data, data ownership, intellectual
property, commercial secrecy, insufficient
transparency, and profiteering
300
.
✓ Funding constraints also have implications on
data cleaning, analysis, storage, which may
ultimately affect the data quality. | ➢ Researchers must plan for sustainability of databank before their studies commence
104,
117
.
➢ A need for consistent application of data policies throughout its lifespan including promoting
scientific and ethical integrity on data
47
.
➢ Governments and funders must increase financial sustainability to support capacity and
infrastructure for databanks and data sharing
167,
169
.
➢ There is also a need to invest in human capital
305,
306,
308
.
➢ Other ways of ensuring sustainability of databanks is through obtaining appropriate liability
insurance
252
.
➢ Public-private-partnership in data management can improve for innovation and development
and sustainability of databanks
300
. A good example can be drawn from , the European Union’s
Data Protection Regulation
300
. |
| F) DATA HARMONIZATION |
|---|
| ✓ Data repositories in Africa are disintegrated.
Consortia are often not homogenously
impractical to developing consortium specific
data sharing guidelines.
✓ Many consortia have specific guidelines which
may make it difficult to integrate data.
✓ Data repositories in Africa largely sits in
research institutions or NGOs or generalist
data repository that are not specific to any
discipline; and project or programme specific
repository
193
. | ➢ Develop an integrated multidisciplinary guideline that is flexible for public and population
health. And which will allow multilayer data sharing for public good
10,
133
➢ Develop stakeholder-centric ecosystems in terms of its principles and policies seeking to
efficiently meet the needs of its members
133
.
➢ Stakeholders must work together, through a bottom up approach, to find common grounds,
policies, and solutions to harmonization challenges
235,
309
. Examples include success of GA4GH,
P3G and H3Africa
42,
310,
311
.
➢ Develop a flexible guideline/policy interoperability and convergence between partners to
facilitate collaboration and platform efficiency
330
. |