If you are involved in research at UVA and you will be leaving UVA, there are some steps you will need to take PRIOR TO YOUR DEPARTURE.
- An Exit Checklist for Faculty has been developed and implemented by the Provost Office.
- Please be aware that you do not have to be a faculty member to use the Exit Checklist.
- It includes very useful information for anyone who might be leaving.
If you have questions after reviewing the Exit Checklist please contact the appropriate IRB office.
- IRB-HSR (Institutional Review Board for Health Sciences Research)
434-924-9634 or 434-924-2620
- IRB-SBS (Institutional Review Board for Social and Behavioral Sciences)
434-924-5999
If you are the Principal Investigator of a protocol, you need to be aware of the following:
- Original study files are considered institutional records and may not be transferred. You are to notify your department administration regarding where the originals will be kept at UVA.
- No data/health information or specimens may be taken from UVA without a signed DataTransfer Agreement between OSP/SOM Grants and Contracts Office and the new institution. The data transfer agreement will delineate what copies of data, health information and/or specimens may be taken outside of UVA. It will also approve which HIPAA identifiers may be taken outside of UVA with the health information or specimens.
- You must have IRB or Privacy Board approval from your new institution for any research data / identifiable** protected health information or specimens you plan to transfer. Once you have IRB or Privacy Board approval you will submit this document to the School of Medicine Office of Grants and Contracts or to the Office of Sponsored Programs (OSP) if you are not in the School of Medicine. Nothing will be transferred until the Data Transfer Agreement is signed by both parties. During transfer, any electronic data with identifiable protected health information (PHI) will be encrypted and any non-electronic PHI/ specimens will be securely maintained against theft or loss. NOTE: Any identifiable health information or specimens collected without consent will NOT be allowed to leave UVA.
- A HIPAA Data Use Agreement will be incorporated into the Data Transfer Agreement to cover any health information you are taking with you that meet the criteria of a Limited Data Set** under HIPAA regulations. If you are taking a Limited Data Set with you, you may not also take a key to the code that would allow you to re-identify the subject. If you have a limited data set to transfer, you will submit it to the IS Decision Support office at researchdata@hscmail.mcc.virginia.edu. They will review it to confirm it meets the criteria of a Limited Data Set under HIPAA regulations. The CDR will provide OSP/SOM Office of Grants and Contracts with this confirmation prior to the Data Transfer Agreement being signed.
- If you have health information that is de-identified** under HIPAA you will submit the file to the IS Decision Support office at researchdata@hscmail.mcc.virginia.edu. They will review it to confirm it meets the criteria of de-identified under HIPAA regulations. Their office will provide OSP/ SOM Office of Grants and Contracts with this confirmation prior to the Data Transfer Agreement being signed.
- Data must be sent in a secure manner:
- Paper documents may be sent via U.S. mail/ FedEx, UPS etc. directly to the former UVA employee
- De-identified data may be sent via email/ FAX, or on a device such as a flash drive or CD.
- Electronic data meeting the criteria of a Limited Data Set or Identifiable Data: The current PI will contact the UVA Information Security Office to determine an appropriate secure method to share electronic data. Email: it-policy@virginia.edu
** If you are unsure if the health information in your files is identifiable, limited data set or de-identified- submit the file to the IS Decision Support office for their review.
Version Date: 6-25-20