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pdfData Portal Confidentiality
Procedures Manual
September 2013
U.S. Department of Health and Human Services (DHHS)
Substance Abuse and Mental Health Services Administration (SAMHSA)
Center for Behavioral Health Statistics and Quality (CBHSQ)
1 Choke Cherry Road
Rockville, MD 20857
Table of Contents
1. INTRODUCTION..................................................................................................................... 2
2. LEGAL BACKGROUND ........................................................................................................ 3
3. THE APPLICATION PROCESS............................................................................................ 5
OVERVIEW.......................................................................................................................................................................5
STEPS IN THE APPLICATION PROCESS ............................................................................................................................... 6
RECEIVING ORGANIZATIONS........................................................................................................................................... 11
MULTIPLE RESEARCH PROJECT TOPICS ......................................................................................................................... 13
4. SECURITY .............................................................................................................................. 14
OVERVIEW..................................................................................................................................................................... 14
DATA AND SOFTWARE IN THE SECURE DATA PORTAL ...................................................................................................... 14
SECURITY REQUIREMENTS ............................................................................................................................................. 15
5. DISCLOSURE REVIEW PROCESS: SAFEGUARDING CONFIDENTIALITY ........ 19
OVERVIEW..................................................................................................................................................................... 19
DISCLOSURE.................................................................................................................................................................. 19
6. SITE INSPECTION................................................................................................................ 22
VIOLATIONS ................................................................................................................................................................... 22
7. MODIFICATIONS TO THE APPLICATION .................................................................... 24
MODIFICATIONS AT ONE RECEIVING ORGANIZATION ..................................................................................... 24
MODIFICATIONS FOR OVERALL PROJECT .......................................................................................................... 24
8. CLOSING OUT A PROJECT ............................................................................................... 26
PROJECT ARCHIVE......................................................................................................................................................... 26
CONFIDENTIALITY ......................................................................................................................................................... 26
PUBLICATIONS............................................................................................................................................................... 26
9. RESPONSIBILITIES ............................................................................................................. 27
PRIMARY CONTACT RESPONSIBILITIES (IN ADDITION TO BEING A PPO) ........................................................................... 27
PPO RESPONSIBILITIES (IN ADDITION TO BEING TEAM MEMBER) ..................................................................................... 27
PROJECT TEAM MEMBER RESPONSIBILITIES ................................................................................................................... 27
CBHSQ RESPONSIBILITIES ............................................................................................................................................ 28
SAMHDA RESPONSIBILITIES ......................................................................................................................................... 28
GLOSSARY................................................................................................................................. 28
APPENDICES ............................................................................................................................. 32
1. Introduction
This Data Portal Confidentiality Procedures Manual is provided to assist organization(s)
interested in obtaining access to Center for Behavioral Health Statistics and Quality (CBHSQ),
Substance Abuse and Mental Health Services Administration (SAMHSA) Confidential Data.
Confidential Data can only be accessed remotely through a secure Data Portal. This virtual
computing environment has been designed with the specific purpose of providing access for
authorized researchers to conduct approved research using Confidential Data that would not
otherwise be available. Data Portal access is only provided through approved computer
location(s) and IP address(es) at the researcher’s organization. Users are required to maintain the
confidentiality of the data utilized within the Data Portal. Researchers cannot transfer data into or
out of the secure Data Portal.
The goal of the Data Portal is to maximize the use of CBHSQ data for important research and
policy analyses, while conforming to Federal law and protecting identifiable data from
disclosure. This manual describes the application process and the computer and data security
requirements that must be followed if the application is approved and the organization is granted
access to the data through the Data Portal.
This Manual was created as a guide to the process for applying for access to CBHSQ
Confidential Data, as well as to explain the laws and regulations and security requirements
governing the use of these data. It serves as a procedures guide and does not replace the
provisions of the actual Confidential Data Use and Nondisclosure Agreement (i.e., data use
agreement).
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2. Legal Background
CBHSQ data are collected pursuant to SAMHSA’s authority under Section 5051 of the Public
Health Service Act (PHS Act). Access to most CBHSQ Confidential Data is covered by a
Federal law called the Confidential Information Protection and Statistical Efficiency Act
(CIPSEA) of 2002 (see P.L. 107-347, Title V) and the Public Health Services (PHS) Act2, as
well as several other Federal laws. CIPSEA restricts the use of information to statistical
purposes only.
In “public-use data” files, individually identifiable information has been recoded or deleted to
protect the confidentiality of survey respondents. Access to public-use data does not require a
license or other contract and is available online to the general public. However, access to
Confidential Data requires a data use agreement (contract) between CBHSQ and the researcher’s
organization. CBHSQ Confidential Data do not include direct identifiers such as name or
address.
There is demand for additional data that is not included in public-use data files. For example,
analysts and policy makers have been interested in estimates at the state and local level, as well
as for certain subpopulations. CBHSQ is required to comply with the confidentiality provisions
of both the PHS Act and CIPSEA. Under the provisions of 501(n) 3 of the PHS Act, information
that is individually identifiable may only be used and released for the purpose for which it was
supplied unless consent was given to use the information for some other purposes. Requesting
access to Confidential Data requires following the requirements of CIPSEA. If a researcher is
granted access to the data, all legal and security requirements for using the data must be met and
implemented.
CIPSEA was enacted as part of the E-Government Act of 20024 and is intended to facilitate data
protection and sharing. In November 2006, the Office of Management and Budget (OMB)
designated CBHSQ as a federal statistical unit. Statistical agencies or units, such as CBHSQ,
may designate agents with whom Confidential Data may be shared, so long as the agent uses the
data for a statistical purpose and the agent agrees to implement security protections as
established by the statistical unit. Violations of the provisions of CIPSEA are subject to five
years imprisonment and/or a fine of up to $250,000.
1
http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=browse_usc&docid=Cite:+42USC290aa-4
See 42 U.S.C. 290aa(n)
3
Section 501(n) states “No information, if an establishment or person supplying the information or described in it is
identifiable, obtained in the course of activities undertaken or supported under section 290aa–4 of this title may be
used for any purpose other than the purpose for which it was supplied unless such establishment or person has
consented (as determined under regulations of the Secretary) to its use for such other purpose. Such information may
not be published or released in other form if the person who supplied the information or who is described in it is
identifiable unless such person has consented (as determined under regulations of the Secretary) to its publication or
release in other form.”
http://frwebgate3.access.gpo.gov/cgi-bin/waisgate.cgi?WAISdocID=54521924645+13+0+0&WAISaction=retrieve
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P.L. 107-347, Title V.
2
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Under CIPSEA, the following provisions apply when CBHSQ shares data for research purposes:
Data can only be made available to “agents” designated by the statistical unit (CBHSQ).
Each agent is an “individual data recipient”.
The data can be used only for statistical purposes.
CBHSQ decides whether individual data recipient’s analysis is safe to release (through a
disclosure review) once disclosure risks in the analysis are minimized.
Data are shared only on an as-needed basis; CBHSQ decides what data are available to
share and when access is appropriate.
Each individual data recipient has to undergo annual CIPSEA training.
Each individual data recipient has to sign a certificate of Designation of Agent and
Affidavit of Nondisclosure form.
CBHSQ is responsible for monitoring individual data recipients and conducting site
inspections for data security compliance.
The CBHSQ Confidential Data access program is designed to comply with the requirements of
both 501(n) and CIPSEA. In addition to 501(n) and CIPSEA, the protection of data with
individually identifiable information is found in other Federal laws such as the Privacy Act of
19745 and the Federal Information Security Management Act of 20026.
The Privacy Act of 1974 (5 U.S.C. 552a) protects the privacy of personal data maintained by
the Federal Government. It imposes numerous requirements upon Federal agencies to safeguard
the confidentiality and integrity of personal data and limits the uses to which one may use the
data. Under the direction of the Office of Management and Budget, Federal agencies issue
policies, standards, and guidelines for protecting personal data. A key standard is the Federal
Information Processing Standard Publication (FIPSPUB) 41, Computer Security Guidelines for
Implementing the Privacy Act of 1974. FIPSPUB 41 provides guidance to ensure that
government-provided individually identifiable information is adequately protected in accordance
with Federal statutes and regulations.
The Federal Information Security Management Act (FISMA) of 2002 (P.L. 107-347, Title
III) requires that each federal agency develop, document, and implement an agency-wide
program to provide security for the information and the information systems that support the
operations and assets of the agency, including those provided or managed by another agency,
contractor, or other source. Under FISMA, information security means protecting information
and the systems it resides on from unauthorized access, use, disclosure, disruption, modification,
or destruction in order to provide integrity, confidentiality and availability.
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5 U.S.C. 552a.
P.L. 107-347, Title III.
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3. The Application Process
Overview
Who Can Apply for Access to Confidential Data?
CBHSQ provides Confidential Data only to qualified organizations in the United States.
Individual researchers must apply through a recognized organization (e.g., a government agency,
university, or research organization). An Application for Access will only be considered if it is
submitted by the Call for Application deadline.
The Principal Project Officer (PPO) will serve as the project contact person at a Receiving
Organization. The Receiving Organization Representative (ROP) is an individual who has the
legal authority to bind the organization to a contract. A ROP must sign the legally binding
contract (i.e., data use agreement) prior to access to CBHSQ Confidential Data.
The PPO must be directly employed at the Receiving Organization (i.e., they cannot be a
contractor, temporary employee, visiting professor or outside consultant to the Receiving
Organization). Research Staff must be directly employed by or students currently enrolled at the
Receiving Organization. At institutions of higher education, the PPO must have an advanced
degree (e.g., Ph.D., J.D., M.D. or Ed.D.). Usually PPOs serve as principal investigators of
research projects or sponsor Ph.D. students conducting dissertation research. Graduate students
may not apply for access and must find a qualified faculty member to apply on their behalf.
The Receiving Organization headquarters, related business offices and/or research site locations
must be located in the 50 United States or District of Columbia. An Application will not be
approved if the Receiving Organization’s place of business is within a private residence.
If there are multiple Receiving Organizations, then a PPO at one of the Receiving Organizations
must be designated on the Application for Access as the Primary Contact for the overall project.
The maximum number of persons who may have access to the Confidential Data during the
project is limited to ten (10). This includes the PPO and Research Staff combined and for
projects that span across multiple organizations.
The Application must clearly outline the nature of the proposed research project as well as the
specific information and categories of variables needed and how this information will be used.
Only the data requested in your application and approved as part of the signed Agreement will be
provided for your use in the Data Portal. Any additional data must be requested and approved
through a formal, signed amendment to the Agreement. Such an amendment would be required
for any data other than that originally requested under the Agreement—including any additional
CBHSQ data files or data from sources.
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As part of the Agreement, the PPO and each Project team member must confirm and implement
the physical security requirements for computer set-up and locations as well as behavioral
security requirements regarding the action of project team members. Section 3 discusses the
security requirements.
To better understand the data, security requirements, and restrictions, please review all of the
documents in the Appendices prior to the submission of your Application form. Also, please see
Appendix 3 for a list of some conditions that must be met for an application to be approved.
The Appendices include copies of the forms for reference but you should download the forms
from the website to ensure that you have the current versions.
If you have any questions, please contact [email protected].
Confidential Data Request
As part of the Application for Access, the PPO must determine which surveys and survey years
are needed for the proposed project. The data currently available are for the National Survey on
Drug Use and Health and the Drug Awareness and Warning Network. The survey years that are
available are listed on the Application for Access. Much of the information on variables is
available through the codebooks for the public-use files. Additionally, a complete listing of all
variables in the Confidential NSDUH Data files is available on the Data Portal website. The
combined examination of the public-use data codebook, the questionnaires, and the Confidential
Data variable lists, may help analysts decide whether the public-use file meets their research
purposes or whether the Confidential Data are needed. You can also contact CBHSQ for more
information on approximate sample sizes (exact sample sizes are confidential).
Other Data Requests
Any request for additional non-CBHSQ data to be used in your research should be requested as
part of your original Application. You will have to make the case for why the data are needed for
your research.
If additional data are requested after the Agreement is signed, then this request is an amendment
to your Application and must also go through an approval process, including a consideration of
potential disclosure issues that arise from combining data sources. If CBHSQ approves, then the
data would be provided through the Data Portal.
Steps in the Application Process
The application process and main project steps are summarized in the flowchart on the next page,
and are described in this section. The names of the documents are in bold italics in the list of
steps. The forms that are needed are available on the SAMHDA website:
www.icpsr.umich.edu/icpsrweb/content/SAMHDA/dataportal.html
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STEP 1 - SUBMIT APPLICATION FOR ACCESS
(i) Complete the Application for Access to Confidential Data which has three sections and a
signature page:
Section A.
o Information for your Receiving Organization: name, title, and contact information
for the Principal Project Officer and all project team members (including all who
will have access to the data), and organization information
o Summary of Experience and Curriculum Vitae
o Description of the Secure Project Office(s) where the data will be accessed
Section B.
o Information for all Receiving Organizations participating in the project
Section C.
o Description of the proposed research project
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o Data requested and why the public-use data file(s) and the Restricted-use Data
Access System (R-DAS) are not adequate for the research project
o Survey years requested
o Request for restricted variables
Original Signature Page.
o Signed by PPO
Important: For more information on Receiving Organizations, how to complete the
Application for Access for projects involving more than one Receiving Organization, or how
a PPO submits multiple research projects, see the section on “Receiving Organizations” and
“Multiple Project Research Topics, as well as the instructions for the Application for Access
form in the Appendix.
(ii) Send the completed Application to SAMHDA by mail or courier to the address below by the
deadline for the Call for Applications. This must be the original paper copy (with original
signatures in blue ink):
For United States Postal Service:
ICPSR/SAMHDA
University of Michigan
Institute for Social Research
P.O. Box 1248
Ann Arbor, MI 48106-1248
For Courier (UPS, Fed EX, DHL, etc.) delivery:
ICPSR/SAMHDA
330 Packard Street
Ann Arbor, MI 48104
(iii) Send a Word version of the Application to SAMHDA. (This does not need to be signed and
does not need to include CVs.)
STEP 2 - REVIEW OF APPLICATION BY SAMHDA AND CBHSQ.
Review Criteria
Since CBHSQ can only approve a limited number of applications, application evaluation criteria
will be used. The primary evaluation criteria are:
The behavioral health impact of the proposed project and its potential contribution and
alignment with Department of Health & Human Services and SAMHSA missions,
How well the research is aligned with the purpose7 for which the data were collected, and
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The Data Portal will initially make Drug Abuse Warning Network (DAWN) and National Survey on Drug Use
and Health (NSDUH) data sets available. For descriptions of these data sets, see DAWN
(http://www.samhsa.gov/data/DAWN.aspx) and NSDUH (http://www.samhsa.gov/data/NSDUH.aspx) resources.
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Whether the data requested is suitable for the proposed research project given data
limitations (available sample size or survey content).
CBHSQ will also consider secondary evaluation criteria as:
Available resources needed by CBHSQ to prepare the data file and the cost of site
inspection.
The experience and capabilities of the research team.
Review Process
SAMHDA reviews each Application for Access to check that it is complete. If not, SAMHDA
requests that the PPO provide the missing information for Application for Access.
It is possible that additional information may be requested by CBHSQ to clarify the information
provided in the Application. If needed, CBHSQ may contact the applicants to discuss aspects of
the Application.
CBHSQ staff will determine if there are enough cases for the proposed analysis and if the
proposed dissemination plan can protect respondent identity from disclosures.
Reasons for non-approval may include confidentiality concerns, inability of data to support
planned analyses (e.g., requested variables not collected or too sensitive or inadequate sample
size), or other reasons, such as incomplete application or unresolved security issues.
Once all Applications have been received from all Receiving Organizations and each is
complete, SAMHDA forwards the Application to CBHSQ for final approval. If CBHSQ
approves the Application, SAMHDA will contact the research team to start the process of
confidentiality training.
Overview of Review Outcomes
SAMHSA/CBHSQ reviews the Application and decides whether to give preliminary approval,
require revisions, or reject the application:
o Preliminary Approval. CBHSQ will verify that only eligible individuals will have access
to the data. When a project has received preliminary approval, SAMHDA provides
usernames and passwords and instructions for the online Data Portal Confidentiality
Training.
o Revise. If revisions are required, SAMHDA notifies the PPO and the PPO revises the
Application and emails it to SAMHDA. (Revisions should be summarized in a cover
note and changes in the Application should be indicated in bold, underline text, in blue
font. The revised application does not require original signatures.)
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o Reject. If the application is rejected (e.g., it is submitted after the deadline), then another
application can be submitted during the next Call for Applications.
STEP 3 - COMPLETE TRAINING AND SIGN DOCUMENTS
(i) Data Portal Confidentiality Training. Each team member (including PPO) must complete
the online Data Portal Confidentiality Training course and read the approved Application for
Access, Confidential Data Use and Nondisclosure Agreement (CDUNA), and the Data Portal
Confidentiality Procedures Manual.
(ii) The PPO and each team member must sign either an Affidavit of Nondisclosure or a
Declaration of Nondisclosure:
Each team member who is not a Federal employee must sign a Designation of Agent and
Affidavit of Nondisclosure form where he/she agrees to abide by CIPSEA requirements
and the Confidential Data Use and Nondisclosure Agreement. This Affidavit must be
notarized. (A copy of the form is in Appendix D.)
If the research team member is a Federal government employee, the team member must
sign the Designation of Agent and Declaration of Nondisclosure form after completing
the confidentiality training. (A copy of the form is in Appendix C.)
Note: All project team members must complete confidentiality training on an annual basis. The
signed nondisclosure form serves to designate a person as an ‘agent’ under CIPSEA.
(iii) The Principal Project Officer (PPO) and the Receiving Organization Representative (who
has the authority to sign legally binding contracts for the Organization) both sign the
Confidential Data Use and Nondisclosure Agreement (CDUNA).
(iv) The PPO sends the original signed, notarized Affidavit(s) or signed Declaration(s) and the
original signed CDUNA to SAMHDA by United States Postal Service or by Courier to an
address listed in Step 1.
STEP 4 - FINAL REVIEW
Step 4 is the final step in the Application and approval process.
Once the original signed CDUNA and Affidavits are received by CBHSQ, CBHSQ review for
completeness. If the CDUNA is complete, then CBHSQ will process it for signature. A copy of
the signed and approved CDUNA will be sent to the PPO. At this point, the PPO and project
team will be authorized to access the Data Portal.
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PROJECT BEGINS
STEP 5 - ACCESS TO DATA PORTAL
SAMHDA forwards a copy of the signed CDUNA, Data Portal User Guide and MTokens to the
PPO.
The project team members follow instructions in the Data Portal User Guide to set up access to
the Data Portal. (Access may only be set up on the computer(s) in Secure Project Office(s) as
listed and approved Application for Access.)
SAMHDA will load the data into the project folders within the Data Portal. Access to these data
is allowed only for approved project members who have signed Affidavits within the last year.
STEP 6 - PROJECT WORK
The project team carries out the approved research.
Disclosure Review and Release of Results. Results can only be released outside of the Data
Portal as approved by CBHSQ. The PPO for the project submits request for disclosure review to
SAMHDA. The results submitted for disclosure review should be in near-final form as would be
needed for publication or presentation. Results that include many results from analytic runs or a
large number of tables or computer outputs are not near-final form and are discouraged. The
review process is covered in Section 5 of this Manual and in the Data Portal User Guide.
All project team members must complete confidentiality training on an annual basis.
STEP 7 - PROJECT END
At the end of the project, SAMHDA stores an archive project folder provided by the Primary
Contact for three years (unless an extension for a longer period of time has been requested and
approved by CBHSQ/SAMHSA prior to expiration date). Also, see Section 8 of this Manual on
“Closing out a Project”.
Receiving Organizations
The Receiving Organization must be an institution of higher education, a research organization,
or a government agency. The Receiving Organization headquarters, related business offices
and/or research site locations must be located in the 50 United States or District of Columbia.
An Application will not be approved if the Receiving Organization’s place of business is within
a private residence.
The Principal Project Officer (PPO) will serve as the contact person for the project at an
individual Receiving Organization and signs the Application for Access and CDUNA. The
Receiving Organization Representative (ROP) is an individual who has the legal authority to
bind the organization to a contract. Only the ROP, as the legal representative for Receiving
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Organization, may sign the legally binding contract required for access to CBHSQ Confidential
Data.
A project may involve one organization with multiple locations or multiple Receiving
Organizations. Each situation is described below:
Single Receiving Organization. If your project involves one organization with researchers at
one or more locations, and the organization is represented by a single Receiving Organization
Representative, then there is one PPO and one Receiving Organization for your project. You
will need to complete only one Application for Access, which lists the researchers for each
location. Each location must also be identified and described.
Multiple Receiving Organizations. If your project involves multiple collaborators at different
Receiving Organizations:
o Each Receiving Organization will need to have a separate PPO and a separate
Application for Access.
o For the Application process, one of the PPOs must be designated as the Primary Contact
with SAMHDA and CBHSQ. The Primary Contact coordinates the Applications from the
Receiving Organizations, including the content of Section B (which lists all the
Receiving Organizations involved in the project) and Section C (which contains the
research proposal and data request).
o Responses for Sections B and C must be identical for applications from all of the
Receiving Organizations. So either…
Applications for all the Receiving Organizations are sent to SAMHDA in one
package, including (i) Application sections for each Receiving Organization that
are specific to the Organization (i.e., Section A, signature page, and curriculum
vitae) and (ii) one copy of Section B and C.
This option is preferred as it facilitates review and processing of the Application.
Or
Each Receiving Organization submits its own application separately. The PPO of
each Receiving Organization inserts the same Section B and Section C content as
coordinated and provided by the Primary Contact. This information must be
included in each Application since this completed Application for Access
document will become part of the contract agreement with the individual
Receiving Organization.
Applications are processed as they are received, but the set of Applications and
project proposal is not reviewed until Applications have been received from all
the Receiving Organizations).
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Multiple Research Project Topics
In response to a single Call for Applications, a PPO can only submit one Application for Access.
However, that Application can encompass several, separate topics of research. All of the research
topics should be covered in Section C. There should be one overall research project title and
responses to questions should encompass all the research topics for all questions except for
Question 11 in Section C. Question 11 describes the proposed research and should be completed
by answering the set of items for an individual topic, and then doing this for each topic in turn.
For example, if a PPO is overseeing several students’ doctoral research work, the students’
research projects should all be covered in one application.
If there are Multiple Receiving Organizations, as discussed above, Sections B and C must be
identical for all the Organizations.
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4. Security
Overview
This section reviews security requirements that cover access control to the Data Portal, secure
locations, and secure use of the data within the Data Portal. Users are required to maintain the
confidentiality of all data within the Data Portal and to scrupulously follow all security protocols
and policies. Users of the Data Portal must follow all the requirements of CIPSEA to protect the
data and prevent disclosure of the identity of individual respondents. A disclosure review of
statistical results must occur before any data or results are permitted to leave the Data Portal.
Only those persons (project team members) listed on the Application for Access to Confidential
Data, who have completed confidentiality training and have a Designation of Agent and
Affidavit of Nondisclosure form on file with CBHSQ or who are approved later through a formal
approved amendment to the Agreement, are authorized to use the Data Portal. Only the data
requested in your Application and approved as part of the signed Confidential Data Use and
Nondisclosure Agreement can be used in your analysis.
As part of each Application, applicants must confirm that their computers and project offices
meet the physical security requirements for computer set-up and locations as required in the
Application and Agreement. All project team members must follow all security requirements for
the duration of the project. In addition, confidentiality requirements for the data do not end at the
completion of the project, but must continually be observed.
Data and Software in the Secure Data Portal
The Data Portal is a system that provides secure access to CBHSQ Confidential Data.
When a researcher logs onto the Data Portal, a separate Windows desktop opens within the
researcher’s own computer desktop. The Data Portal is connected to a server at ICPSR. The Data
Portal is virtually isolated from the user’s local, physical desktop computer. For each project
team, there is a workspace with the directory of folders for the project. The workspace will
contain the Confidential Data required for the user’s specific research project. The project team
may create their own folder sub-structure as needed within the overall project folder. A user will
not be able access the content of any other researcher’s project folders.
Providing access through the Data Portal minimizes the possibility that a researcher could
inadvertently or purposefully release Confidential Data to unauthorized persons. The Data Portal
prevents users from emailing, ftp’ing, copying, or otherwise moving files or information outside
of the Data Portal or moving files or other data into the Data Portal, either accidentally or
intentionally. It also blocks unauthorized access to the data from unauthorized persons.
Within the Data Portal, users can analyze data, write papers, and produce reports using their own
computer, but it won’t be possible to share information between the user’s local computer and
the Data Portal virtual computer.
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The following software is provided in the Data Portal:
SAS 9.3 including the Education Analytical Suite, SAS Enterprise Miner Client,
SAS/GIS, and SAS/SPECTRAVIEW;
SPSS 19 including the add-ons for Regression Models and Advanced Models;
STATA 12;
SAS-Callable SUDAAN 11.0.0;
Stat Transfer 9;
R (programming language only; no modules); and
Microsoft Office 2010 (Access, Excel, InfoPath, OneNote, PowerPoint, Publisher, and
Word).
Users can write their own programs within the Data Portal using the software available. Users
will not be able to import programs into the Data Portal. If a project team needs to use their own
previously developed analysis program, the program will need to be submitted to the Data Portal
user support group with a request to move it into the project team’s Data Portal folder. However,
this needs to be described in the Application along with any other software needed which is not
provided in the Data Portal.
Security Requirements
Access Control
Under no circumstances, can any unauthorized person be allowed to access the Data Portal.
Login. The access control procedures at login verify the IP address, username, and password.
Only the desktop computer at the approved IP address (or within approved range of addresses for
organization) can be used to login to the Data Portal. (Other IP addresses are blocked by a
firewall protecting the Data Portal.) Only strong passwords8 are allowed. The Data Portal will
time out and lock after a few minutes of user inactivity. The user will be required to enter the
password to unlock the Data Portal desktop. SAMHDA maintains audit logs for monitoring
researcher behavior during data access and use.
Passwords. Protect passwords. Login credentials must be used correctly and not given to any
person. A user’s Data Portal password must not be shared with anyone else, either intentionally
or through lack of security (such as using a saved password list outside the Data Portal in
electronic or written form). Passwords cannot be shared with your IT support people. (You may
8
When you change your password, your new password will be checked for strength by the ICPSR/University of
Michigan IT system. The password must use nine or more characters, with characters in at least three of the
following categories: lowercase letters, uppercase letters, numerals, and punctuation. It must not be a word or simple
phrase or use parts of your name. For example, the user can make a strong, easy to remember password by using the
first letters of the words in a phrase and converting some words to number as in "Four score and seven years ago our
forefathers brought forth" is 4S&7yaofb4th. The user should also select a unique password for Data Portal use. Do
not use a password that you currently use or one that was used for other past computing accounts.
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contact your institution’s IT staff if you need help installing the VMware client software before
you access the Data Portal, but IT staff should never be allowed to access the Data Portal or view
content within the Data Portal.)
MToken. An approved user will be issued an MToken. The MToken generates a random number
that is used to login along with the user’s login ID and password. This MToken must not be
shared with anyone. If the MToken is lost, you must report it to [email protected].
When a team member leaves the project, the MToken must be returned to SAMHDA, ICPSR,
University of Michigan, P.O. Box 1248, Ann Arbor, MI 48106-1248
Logoff or disconnect. If you are logged into the Data Portal and you leave your computer, you
must “disconnect” or “logoff” from the Data Portal. (Disconnecting from the Data Portal will
leave any open programs running, but closes the connection to the Data Portal. Logging off of
the Data Portal closes the connection and terminates all programs that are running.)
Password-protected screensaver. The approved computer must have a password-protected
screensaver installed and set to activate within 3 to 5 minutes of inactivity. However, automatic
time outs or screensavers are not sufficient access control, as they leave the Data Portal open to
access by others.
Security patches. The desktop computer must be maintained with security patches and up-todate anti-virus software enabled.
Data cannot be moved in or out of the Data Portal. The Data Portal prevents users from
emailing, ftp’ing, copying, or otherwise moving files outside of the secure environment, either
accidentally or intentionally. The Data Portal prevents unauthorized access to data from outside
persons by using secure access controls and firewalls.
If you become aware of any unauthorized access, use, or disclosure of Confidential Data,
whether suspected or actual, this unauthorized access, use, or disclosure of Confidential
Data must be reported immediately to CBHSQ and SAMHDA/ICPSR via phone call to
CBHSQ (240-276-1273 and 240-276-1364) and SAMHDA (888-741-7242) followed-up with
an email to CBHSQ ([email protected] and [email protected]) and
SAMHDA ([email protected]).
Secure Project Office and Computers
Only computers at the authorized IP addresses can access the Data Portal. These computers must
be secure from access by unauthorized persons by being placed in a designated and approved
Secure Project Office. The computer must be a desktop model and the internet connection must
be hard wired. A wireless connection is not allowed for connecting to the Data Portal.
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As part of the security Data Portal protocol, only computers using Windows can be used to
access the Data Portal. (If Macs are allowed in the future, you can submit a request to modify
your approved computer to include a Mac computer.)
The computer must be placed inside a Secure Project Office where only authorized persons can
view the computer screen when data are displayed. You may add a second screen for your
computer so that results are more easily viewed by one or more authorized persons at the same
time. The screens must not be visible from outside the office by anyone.
The computer location must be within a walled office and be secured with a lockable door. No
unauthorized persons are allowed inside the office when the data are in use. The office should be
locked and the Data Portal should be locked when team members temporarily leave and do not
logoff or disconnect from the Data Portal.
Use of a cubicle as a Secure Project Office is not allowed. (A project team can have more than
one Secure Project Office, e.g., team members may work in separate Secure Project Offices.)
No telecommuting or remote access from unauthorized locations is allowed. Attempts to access
the Data Portal through remote connection using an authorized computer, but from an
unauthorized location is a serious violation and may result in penalties or denial of access for the
person and/or the project team.
All conversations about the Confidential Data, analyses, and results must only be conducted
among authorized project team members in a secure location. These discussions should only
take place within the confines of the Secure Project Office where unauthorized persons cannot
overhear the discussions. In general, these kinds of conversations must not be conducted in
public locations where unauthorized persons could overhear such discussions.
Secure Use of Data
Analysis and use of data can only be done within the Data Portal. Recording data or results and
then moving them outside of the Data Portal is not allowed. This means that no screenshots,
photographs, or videos may be made of the displayed data or output. No copies of data may be
made (e.g., no retyping or copying data, such as handwritten notes). In addition, cameras and
other video equipment are not allowed to be present inside the Secure Project Office when the
Data Portal is in use. Recording data or results and then moving them outside of the Data Portal
is a serious violation and may result in penalties or denial of access for the person and/or the
project.
Disclosure review and approval is required before any analysis results or findings can be released
in any form or discussed outside the authorized project team. Without a disclosure review and
approval from SAMHDA/ICPSR and CBHSQ, you cannot share or discuss the data or results
with unauthorized persons.
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You can discuss the type of research you are doing, e.g., the hypotheses you are testing, with
others outside your authorized project team, but you cannot discuss any data or results, due to
potential disclosure risk.
Authorized persons can discuss general questions with the SAMHDA user support team at
SAMHDA/ICPSR or the SAMHDA COR if requested to do so as part of user support or to
report a disclosure issue. However, never send any information with Confidential Data through
email, even if reporting a disclosure issue.
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5. Disclosure Review Process: Safeguarding Confidentiality
Overview
Analysis results must go through the disclosure review process at SAMHDA/ICPSR and
CBHSQ before they can be discussed or viewed by anyone who is not on the project team as
listed in the Application. After analysis is completed, the program results, report, or presentation
files created within the Data Portal must undergo a disclosure review to assess output for
disclosure risk. The purpose of the disclosure review is to protect respondent confidentiality. It
is not a review of research quality or findings.
Only near-final results intended for publication or presentation should be submitted for
disclosure review. Analysis results remain in the Data Portal until the disclosure review process
has been completed. Since, users cannot export any files or documents out of the Data Portal,
SAMHDA will deliver results (cleared during the disclosure review process) to the project team
for use outside the Data Portal. Only after disclosure review approval has been obtained can
results be discussed, reviewed, presented, or released to persons outside of the authorized project
team.
Disclosure
Disclosure occurs if it is possible from the analysis or results to determine the value of some
characteristic of an individual entity. Identification may occur when data are combined with
other data sources. Identification may also occur in aggregated statistics. For example, a table
cell that includes only one respondent in combination with other knowledge could make
identification possible.
Key rule: Do not attempt to identify an individual respondent (e.g., whether person, organization,
or establishment.) You must immediately report inadvertent identification or disclosure of
Confidential Data to SAMHDA and CBHSQ.
In addition to the penalties associated with CIPSEA, any violation of Federal law or the terms in
the Agreement may be reported to the Research Integrity Officer, Institutional Review Board, or
Human Subjects Review Committee of the user's institution. A range of sanctions are available
to institutions including revocation of tenure and termination. If the confidentiality of human
subjects has been violated, the case may be reported to the Federal Office for Human Research
Protections. This may result in an investigation of the user's institution, which can result in
institution-wide sanctions including the suspension of all research grants.
Guidelines for Researchers to Avoid Disclosure
Limit analyses to those proposed and approved in your Application.
Avoid analyses involving small sample sizes (e.g., cells with less than 5 respondents). It is
better to combine small groups rather than eliminating records from an analysis.
Avoid creating tables that are very similar but with very small differences in categories used
in the analysis.
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Do not report any unweighted sample size numbers except a limited number of overall
sample size numbers rounded to the nearest 100.
Do not report any unweighted percent distributions.
Preparing Your Analyses for Disclosure Review
Use titles for each analysis being presented for disclosure review.
Specify the dataset(s), variables, and sample/sub-sample from which the outputs have been
derived. Describe how the output will be used (e.g., presentation, publication).
Avoid submitting peripheral or interim output or documents for disclosure review, i.e., output
or documents that will not appear in publication or be disseminated. While these kinds of
output and documents can be produced, their use should be within the Data Portal. Also,
release of these items may create complementary disclosure risks through the combination of
information from different sources or sub-samples. Exploratory descriptive analysis,
preliminary regression models, or draft papers are examples of peripheral output or
documents which should not be submitting for a disclosure review.
Important note: The project team must consider the analyses and release of results in the context
of the work of the entire project. The team may want to delay asking for disclosure review for
results until a later date. For example, an early result that has been reviewed and cleared for
release could cause a disclosure risk for subsequent results if both results were combined. Once
analyses are approved for release, SAMHDA and CBHSQ assume approved results will be
disseminated by the project team. So results approved for release could impact what else can be
approved for later release.
Initiating Disclosure Review. If any project team members want to release results outside the
project team, these results (whether a report or presentation files) are placed into the “FOR
SAMHDA REVIEW” folder for disclosure review. These files are then reviewed by SAMHDA
staff, a Disclosure Review Board, and CBHSQ staff. The PPO sends an email to
[email protected] requesting a disclosure review for the file named in the review
folder.
Release of Results from the Data Portal. Once the results are approved, the files and/or edited
version of files are deposited into the folder “SAMHDA REVIEW COMPLETED.” Since users
cannot export from the Data Portal, SAMHDA will deliver approved results to the PPO usually
via email.
Disclosure review. SAMHDA will work with CBHSQ to identify any disclosure risks in the
results or documents. CBHSQ will make the final determination regarding final approval for
release. The determination of the presence of disclosure risks will not focus on scientific merit or
policy relevance of the analyses. If CBHSQ determines there are disclosure risks, the researcher
is not authorized to publish or disseminate the results. CBHSQ’s decision is final.
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Researchers who avoid the disclosure review process and use or publish data outside of the Data
Portal without CBHSQ approval commit a serious violation of the Agreement. Such violations
may result in penalties or denial of data access for the person and/or the project.
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6. Site Inspection
Based on CIPSEA requirements, CBHSQ will conduct announced or unannounced site
inspections during the period that project researchers have access to the data. A site inspection of
the project team members’ site(s) is to assess and ensure compliance with the provisions of the
Agreement. This also includes an assessment of the current status of the project.
The site investigator will review the project operations and security procedures with the Principal
Project Officer, or other senior project team member (as listed in the Application).
The inspector will review the names and status of all project team members. All project team
members must have a signed, notarized Designation of Agent and Affidavit of Nondisclosure
form on file with SAMHDA (see Checklist for Application in Section 3.) This review is to
confirm that SAMHDA and CBHSQ have the most current information on file for those
individuals who are authorized to access the data.
The investigator will check to ensure that the Application, Agreement, Affidavits and training
materials have been reviewed by all project team members. All project team members must
know and understand all of the security procedures required for accessing Confidential Data.
Violations
Statement of Warning. If the investigator finds the site to be noncompliant where an
unauthorized disclosure could occur, CBHSQ will send a Statement of Warning to the PPO
within two weeks (10 working days) of the site inspection. (More serious violations may result in
immediate revocation of Data Portal access and/or criminal prosecution.) The PPO and project
team has one week (5 working days) from receipt of the Statement of Warning to remedy the
violations, and to send a response to the CBHSQ describing the remedies and results.
Any violation found through the site inspection may subject the PPO and project team members
to immediate denial of Data Portal access or a report of the violation to the U.S. Attorney.
Penalties, fines and imprisonment, may be enforced for each occurrence of such violations.
Revocation of access. Any violation of the terms and conditions contained in the Agreement
(and documents included by referral) may subject the project and research team members to
immediate revocation of access to the Data Portal. If violations are discovered, CBHSQ will
notify the PPO in writing of the factual basis and grounds for revocation. CBHSQ shall provide
written notice of a decision to the PPO after receipt of the PPO’s written argument.
Most Common Violations
No three to five minute shutdown through use of a password protected screensaver
Attempting to access Confidential Data from an unauthorized location
PPO not maintaining control over access to the Confidential Data
PPO neglecting to inform CBHSQ of any project personnel changes
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Making use of or copying the Confidential Data and taking it outside of the Data Portal
before a disclosure review is conducted
Discussing Confidential Data in non-secure locations
Not locking the Secure Project Office when project team members temporarily leave the
office
Allowing unauthorized persons to view any information displayed in the Data Portal when it
is in use
Prosecution and Penalties. Alleged violations of the Privacy Act of 1974 or CIPSEA are subject
to prosecution by the United States Attorney after first making reasonable efforts to achieve
compliance.
Any violation of the terms of the Agreement and Affidavits (and other documents included by
referral) may also be a violation of Federal law under the Privacy Act of 1974 (5 U.S.C. 552a)
and may result in a misdemeanor and a penalty of up to $5,000.
Anyone violating the confidentiality provisions of CIPSEA by making an unauthorized
disclosure of the Confidential Data could be found guilty of a class E felony and be imprisoned
for up to five years, and/or fined up to $250,000.
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7. Modifications to the Application
The PPO shall keep CBHSQ informed of any modifications in project operations, conditions, or
location that would alter what was described in the Application throughout the span of the
Agreement period. Requests for modifications to the original Application must be submitted by
the PPO to CBHSQ. All correspondence with CBHSQ and SAMHDA must be initiated by the
PPO.
MODIFICATIONS AT ONE RECEIVING ORGANIZATION
Adding Team Members to the Project
A PPO may request the addition of new project team members by submitting the name and
contact information to SAMHDA. CBHSQ will determine if the person is eligible. If the person
is eligible, SAMHDA will then conduct training, and obtain the signed and notarized
Designation of Agent and Affidavit of Non-disclosure from the new team member. SAMHDA
will notify the PPO if the new team member is authorized for access to the data.
Departing Team Members
The PPO will notify SAMHDA and CBHSQ in writing of changes in the Research Staff.
CBHSQ shall be informed 6 weeks prior to a team member’s departure when a person will no
longer be working on the project. Research Staff separation from the Receiving Organization
will lead to the termination of their access to the Data Portal.
Change in PPO
The PPO will notify CBHSQ in writing in the event the PPO plans to separate from the
Receiving Organization during the Contract Period, at least 4 weeks prior to the last day on the
project. PPO separation from the Receiving Organization will lead to the termination of access to
the data for the entire research team at that Receiving Organization, unless the Receiving
Organization identifies and obtains CBHSQ approval of a new PPO.
The Receiving Organization will obtain approval from CBHSQ prior to transferring the
Agreement to another PPO at the same Receiving Organization. In order to obtain such approval,
the PPO must inform CBHSQ in writing 6 weeks prior to the proposed date of transfer, submit a
complete copy of the Agreement signed by the Receiving Organization Representative and the
new PPO, and maintain responsibility for the Computer and Data Security requirements until the
transfer Agreement has been approved by CBHSQ.
MODIFICATIONS FOR OVERALL PROJECT
Agreement Extension
If an extension of time is needed, the Primary Contact from the Application process must submit
a written request to CBHSQ and SAMHDA 3 months prior to the end of Agreement time period
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with a justification for the additional time. Any modifications in the scope of the original project
must be explicitly described in the extension justification.
Change in Research Plan or Computer Environment
If during the course of research there are needed changes to research plans or in the computer
environment that is different from the information originally submitted in the Application,
different from that which is required in the Agreement, and/or is different from that the
Computer and Data Security Requirements in Appendix B of the Agreement, then the PPO must
send CBHSQ a copy of the revised materials and a memorandum describing the changes. These
revisions will be considered amendments to the Agreement and may not be implemented until
written approval is obtained from CBHSQ.
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8. Closing out a Project
Project Archive
Prior to the end of the project, SAMHDA will send an e-mail to the PPO (or Primary Contact if
multiple Receiving Organizations) notifying the project team to create an archive folder. The
email will have the instructions for the required format for items in the archive folder (e.g.,
syntax/code, output, notes, and minimal data due to space limitations). The e-mail will request
acknowledgement by the PPO of the receipt of the e-mail.
The PPO then prepares the archive folder and then sends an email to [email protected]
that the archive folder is ready.
The archive folder is moved to the Archive location. The project folder on the Data Portal is
deleted. Access to the Data Portal is removed for all members of the project team.
After three years, a courtesy e-mail is sent to the PPO prior to permanently deleting the archived
folder.
If access is required by the project team to the material in the archive folder during the archive
period, the PPO or other team member sends a request to [email protected].
If the PPO and project team find that they need access to their Archive for longer than three
years, they will need to submit a request prior to the end of the three year archive period and the
reason for the extension. If the request is approved, access will be allowed for the additional
approved period.
Confidentiality
Confidentiality requirements for the data do not end at the completion of the project, but must
continually be observed.
Publications
Any publications based on the Confidential Data must cite the data source. The citation or the
actual final publication must be sent to [email protected].
Only material or results that have been approved for release by CBHSQ (after a disclosure
review and approval) can be used or referenced outside the Data Portal.
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9. Responsibilities
The PPO, research team members, CBHSQ, and SAMHDA have separate and shared
responsibilities for project support, communication, and ensuring that all security and
confidentiality requirements are met and implemented.
Primary Contact Responsibilities (in addition to being a PPO)
Responsible for the Application process phase with SAMHDA and CBHSQ.
At the end of the project, the Primary Contact prepares the archive folder and notifies
[email protected] that the archive folder is ready.
PPO Responsibilities (in addition to being team member)
Serve as a liaison between CBHSQ and all project team members at the PPO’s Receiving
Organization.
Follow all security procedures as outlined in the Data Portal Confidentiality Procedures
Manual, Training Materials, Affidavits, and the Agreement.
Inform CBHSQ and Primary Contact of any willful or inadvertent violations of the
provisions set forth in the above stated documents.
Ensure that all team members included in the Application follow the guidelines established
by CBHSQ for access to the Confidential Data.
Serve as a liaison between the Primary Contact and all project team members.
Inform CBHSQ and Primary Contact if he/she (PPO) will be moving to another organization
6 weeks prior to the move.
Inform Primary Contact and CBHSQ as soon as possible when staff are to join the project.
The new project staff will need to be approved by CBHSQ prior to their access to the data.
Notify CBHSQ and SAMHDA immediately of any legal, investigatory or other demand for
the Confidential Data.
Make sure all project work is compliant with the requirements established in the Agreement
(including other documents by referral).
Provide all publications, presentations, and reports that use Confidential Data to CBHSQ for
a disclosure review prior to disseminating them outside of the Data Portal.
Report loss of a MToken to [email protected].
At the end of the project, the Primary Contact prepares the archive folder and notifies
[email protected] that the archive folder is ready.
At the end of the project, all MTokens issued to project team members must be returned to
SAMHDA, ICPSR, University of Michigan, P.O. Box 1248, Ann Arbor, MI 48106-1248.
Project Team Member Responsibilities
Follow all security procedures as outlined in the Data Portal Confidentiality Procedures
Manual, Training Materials, Affidavits, and the Agreement.
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Inform the PPO and CBHSQ of any willful or inadvertent violations of the provisions set
forth in the above stated documents.
Inform the PPO of any plans to depart the project team at least 6 weeks before leaving the
project.
Report loss of a MToken to [email protected].
Return the MToken to SAMHDA, ICPSR, University of Michigan, P.O. Box 1248, Ann
Arbor, MI 48106-1248 when team member leaves project.
CBHSQ Responsibilities
Accept, review, and approve or disapprove all Applications for data access. Communicate
with requestor to clarify any issues as needed.
Help to determine scope of project-specific Confidential Data files. CBHSQ will work with
requestor to determine the content of a limited set of variables that are within the scope of the
project as described in the Application.
Help to evaluate Application materials related to access to the Confidential Data.
Develop annual confidentiality training for all agents.
Maintain Affidavits, track new and departing staff on all projects, and monitor data access
expirations and renewals.
Conduct or delegate site inspections.
SAMHDA Responsibilities
Maintain the Data Portal.
Manage user Data Portal accounts.
Provide user support for the Data Portal.
Provide annual confidentiality training for all agents.
Retain Archive folder of project files provided by Primary Contact for 3 years after the end
of the Agreement.
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Glossary
Agent: An agent is a person designated by CBHSQ to perform statistical activities authorized by
law (e.g.: CIPSEA) as specified in a written legal agreement under the supervision or control
of CBHSQ staff. Agents agree in writing to comply with all provisions of law that affect the
activities conducted on behalf of the agency. Agents are a PPO and all other project team
members.
Center for Behavioral Health Statistics and Quality (CBHSQ): The Substance Abuse and Mental
Health Services Administration (SAMHSA), Center for Behavioral Health Statistics and
Quality collects and reports on national and State data to assist policymakers, treatment
providers and patients to make informed decisions regarding the prevention and treatment of
mental and substance use disorders. More information can be found at
http://www.samhsa.gov/about/cbhsq.aspx.
Confidential Data: CBHSQ Confidential Data do not contain direct identifiers, but the data likely
contains information that might lead to respondent identification. Thus, the data are
confidential and are not released to any person outside CBHSQ without appropriate legal
agreements and other documents in place. Confidential data files may contain more variables,
such as demographic and geographic variables, and larger samples than the public-use files.
Confidential data are only accessed through the Data Portal. All security requirements for
accessing the Data Portal and use of the data must be followed. No data, analyses, or results
based on the Confidential Data can be released in any form without a disclosure review and
approval by CBHSQ/SAMHDA. Releasing results before a disclosure review is completed is
a violation of the terms of the Agreement and as such is subject to penalties.
Confidential Data Use and Nondisclosure Agreement: This is the legally binding contract used
by CBHSQ to authorize access to Confidential Data through the Data Portal. The Agreement
specifies the obligations imposed on the signatories and the procedures and security
requirements that must be followed to protect the data.
Confidentiality and Information Protection and Statistical Efficiency Act (CIPSEA): CIPSEA is
Title V of the E-Government Act (P.L. 107-347) and provides strong confidentiality
protections for statistical information.
Contracting Officer’s Representative (COR): A Federal employee appointed in writing and
delegated limited responsibilities by a Contracting Officer (CO) to perform specified contract
management duties related to technical oversight and administration of a specific contract.
Data Portal: The secure computer environment used by authorized users for remote access to
Confidential Data. The Data Portal is part of SAMHDA/ICPSR and was developed under the
contract with CBHSQ/SAMHSA.
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Designation of Agent and Affidavit of Non-disclosure: A form that is completed by a person who
will have access to Confidential Data. This form contains: (1) the wording of an oath not to
disclose such information to persons not similarly sworn, (2) a description of the penalties for
such disclosure, and (3) a section for signature and imprint of a notary public.
Direct identifiers: Direct identifiers include information such as names, addresses, social
security numbers and phone numbers that can be used to specifically identify a
responding entity.
Disclosure: The release of confidential information to any unauthorized person.
ICPSR: The Interuniversity Consortium for Political and Social Research. It is a center within
the Institute for Social Research at the University of Michigan.
Indirect Identifiers: Indirect identifiers include data such as local geography, detailed racialethnic characteristics, or other characteristics, when used together could potentially lead to
the disclosure of a responding entity’s identity.
Individually Identifiable Information: Identifiable information refers to information that can be
used to establish individual or establishment identity, whether directly—using items such as
name, address, or unique identifying number—or indirectly—by linking data about
respondents with external information that directly identifies them.
Nonstatistical Use of Data: Using the data in identifiable form in a way that would affect the
rights, privileges, or benefits of a responding entity. Examples of a nonstatistical use of the
data include using the data for an administrative, regulatory, law enforcement, or judicial
purpose; and releasing the data through a Freedom of Information Act (FOIA) request.
Principal Project Officer (PPO): The PPO is the researcher in charge of the day-to-day
operations at a Receiving Organization involving the use of the Confidential Data. This
person will be the point of contact for the Receiving Organization to coordinate with CBHSQ
and SAMHDA. The PPO signs the Confidential Data Use and Nondisclosure Agreement.
Primary Contact: The Primary Contact is the PPO who coordinates and is the main point of
contact for the Application process. The Primary Contact is responsible for the liaison with
CBHSQ.
Public-use File (PUF): Public-use data files are data files prepared by CBHSQ with the intent of
making them available to the public without restrictions. CBHSQ public-use data files may
not contain all variables, cases or any direct identifiers, and may have undergone other
procedures to limit the risk of disclosing a respondent’s identity.
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Recertification: The process of annual confidentiality training and signing a Designation of
Agent and Affidavit of Nondisclosure to ensure agent’s continued understanding and
implementation of security procedures as required by the Agreement.
Receiving Organization Representative (ROP): The ROP is the individual who has the legal
authority to bind the organization to a contract or data use agreement. The ROP is
responsible for signing the legally binding documents required for approval to access
Confidential Data. With his/her signature, the ROP certifies that: (1) the organization has the
authority to undertake the commitments in the Confidential Data Use and Nondisclosure
Agreement and (2) he/she has the authority to legally bind the organization to the provisions
of the Agreement.
SAMHDA: the Substance Abuse and Mental Health Data Archive that is housed at ICPSR under
contract with CBHSQ.
Statistical Use of Data: Using data for statistical purpose includes the description, estimation, or
analysis of the characteristics of groups, without identifying the individuals or organizations
that comprise such groups. It includes development, implementation, or maintenance of
methods or procedures to support these purposes. Making policy- or program evaluationrelated decisions based on aggregated data that do not identify or specifically target the
individual respondents is a statistical use.
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APPENDICES
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Appendix 1
Application for Access to Confidential Data
The Center for Behavioral Health and Statistical Quality (CBHSQ), Substance Abuse and Mental
Health Services Administration (SAMHSA) has developed the Data Portal for accessing CBHSQ
Confidential Data. The Data Portal is accessed via the web through the Substance Abuse and
Mental Health Data Archive (SAMHDA). SAMHDA is located at the Inter-university
Consortium for Political and Social Research (ICPSR), Institute for Social Research, University
of Michigan (UM).
INSTRUCTIONS: Please use this application to apply for access to CBHSQ Confidential Data.
You will need to describe your research project, specify the data you need, list all members of
your project team, and describe the Secure Project Office(s) where the data will be accessed.
Please see the Data Portal Confidentiality Procedures Manual for more information and
requirements. Applications must be submitted on paper as original signatures are required. The
Manual and other information about the Data Portal is available at
www.icpsr.umich.edu/icpsrweb/content/SAMHDA/dataportal.html
WHO CAN APPLY FOR ACCESS TO CONFIDENTIAL DATA?
CBHSQ provides Confidential Data only to qualified organizations in the United States.
Individual researchers must apply through a recognized organization (e.g., a government agency,
university, or research organization). An Application for Access will only be considered if it is
submitted by the Call for Application deadline.
The Principal Project Officer (PPO) will serve as the primary project contact person at the
Receiving Organization. The Receiving Organization Representative (ROP) is an individual who
has the legal authority to bind the organization to a contract. A ROP must sign the legally
binding contract (i.e., data use agreement) prior to access to CBHSQ Confidential Data.
The PPO must be directly employed at the Receiving Organization (i.e., they cannot be a
contractor, temporary employee, visiting professor or outside consultant to the Receiving
Organization). Research Staff must be directly employed by or students currently enrolled at the
Receiving Organization. At institutions of higher education, the PPO must have an advanced
degree (e.g., Ph.D., J.D., M.D. or Ed.D.). Usually PPOs serve as principal investigators of
research projects or sponsor Ph.D. students conducting dissertation research. Graduate students
may not apply for access and must find a qualified faculty member to apply on their behalf.
The Receiving Organization headquarters, related business offices, and/or research site locations
must be located in the 50 United States or District of Columbia. An Application will not be
approved if the Receiving Organization’s place of business is within a private residence.
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If there are multiple Receiving Organizations, then a PPO at one of the Receiving Organizations
must be designated on the Application for Access as the Primary Contact for the overall project.
The maximum number of persons who may have access to the Confidential Data during the
project is limited to ten (10). This includes the PPO and Research Staff combined and for
projects that span across multiple organizations.
The Application must clearly outline the nature of the proposed research project as well as the
specific information and categories of variables needed and how this information will be used.
Only the data requested in your application and approved as part of the signed Agreement will be
provided for your use in the Data Portal.
RECEIVING ORGANIZATIONS
The Principal Project Officer (PPO) will serve as the contact person for the project at an
individual Receiving Organization and signs the Application for Access for that Receiving
Organization. The Receiving Organization Representative (ROP) is an individual who has the
legal authority to bind the organization to a contract. As the legal representative of the
Receiving Organization, only the ROP may sign the contract required for access to CBHSQ
Confidential Data. A project may involve one organization with multiple locations or multiple
Receiving Organizations. Each situation is described below with instructions on how to
complete the Application for Access.
Single Receiving Organization. If your project involves one organization with researchers at
one or more locations, and the organization is represented by a single Receiving Organization
Representative, then there is one PPO and one Receiving Organization for your project. The
PPO is also the Primary Contact with SAMHDA and CBHSQ for the project. You will need
to complete only one Application for Access, which lists the researchers for each location.
Each location must also be identified and described.
Multiple Receiving Organizations. If your project involves multiple collaborators at different
Receiving Organizations:
o Each Receiving Organization will need to have a separate PPO and a separate
Application for Access.
o One of the PPOs must be designated as the Primary Contact with SAMHDA and CBHSQ
for the overall project. The Primary Contact coordinates the Applications from the
Receiving Organizations, including the content of Section B (which lists all the
Receiving Organizations involved in the project) and Section C (which contains the
research proposal and data request).
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o Responses for Sections B and C must be identical for applications from all of the
Receiving Organizations. So either…
Applications for all the Receiving Organizations are sent to SAMHDA in one
package, including (i) Application sections for each Receiving Organization that
are specific to the Organization (i.e., Section A, signature page, and curriculum
vitae) and (ii) one copy of Section B and C.
This option is preferred as it facilitates processing and review of the Application,
but is not required.
Or
Each Receiving Organization submits its own application separately. The PPO of
each Receiving Organization inserts the same Section B and Section C content as
coordinated and provided by the Primary Contact. This information must be
included in each Application since this completed Application for Access
document will become part of the contract agreement with the individual
Receiving Organization.
Applications are processed as they are received, but the set of Applications and
project proposal is not reviewed until Applications have been received from all
the Receiving Organizations.
Multiple Research Project Topics
In response to a single Call for Applications, a Primary Contact can only submit one Application
for Access. However, that Application can encompass several, separate topics of research. All
the research topics should be covered in Section C. There should be one overall research project
title and responses to questions should encompass all the research topics for all questions except
for Question 11 in Section C. Question 11 describes the proposed research and should be
completed by answering the set of items for an individual topic, and then doing this for each
topic in turn. If there are Multiple Receiving Organizations, as discussed above, Sections B and
C must be identical for all the Organizations.
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SECTION A. Information for Your Receiving Organization
Name of Receiving Organization
PROJECT TEAM
1. Principal Project Officer (PPO) Contact Information
Name of PPO
Title
Department (if
applicable)
Organization
Name
Organization
URL
Phone
Fax
Email
(physical location—also include building name, room number)
Work Site
Street Address
Mail Address
(for mail/package delivery by USPS)
Courier
Address
(for package delivery by courier)
Federal
Employee?
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2. Contact Information for Project Team Members:
Please complete the following information for each additional project team member.
Note: The maximum number of researchers for the project (including all Receiving
Organizations) is limited to 10.
(i)
Team Member
Name of Team
Member
Title
Department (if
applicable)
Organization
Name
Organization
URL
Phone
Fax
Email
Work Site Street (physical location—also include building name, room number)
Address
Mail Address
(for mail/package delivery by USPS
Courier Address
(for package delivery by courier)
Describe the person’s role on the Project Team:
Is this person a Federal Employee?
Additional Team Members: Copy all items from the table above into the space below and fill in
for each additional team member.
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Receiving Organization Representative (ROP)
3. Contact Information for the Receiving Organization Representative (only those persons
who are authorized to sign contracts on behalf of the organization should be listed here):
Name
Title
Department (if
applicable)
Receiving
Organization
Name
Organization
URL
Phone
Fax
Email
Work Site Street
Address
(physical location—also include building name, room number)
Mail Address
(for mail/package delivery by USPS)
Courier Address
(for package delivery by courier)
Federal
Employee?
Organization Certification Number
4. If you are employed at an organization that has a current NIH Multiple Project Assurances
(MPA) Certification Number or Federal Wide Assurances (FWA) Certification Number,
please provide this number and expiration date. (Once you provide this number and date,
you do not need to respond to question number 5 below.)
MPA Number:
FWA Number:
Expiration Date of MPA/FWA Certification Number:
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5. If your organization does NOT have an NIH Multiple Project Assurances (MPA) Certification
Number or Federal Wide Assurances (FWA) Certification Number, please answer the
following questions:
a. Please describe your organization in detail. Include the type of organization, profit/nonprofit status, and primary sources of revenue.
b. What is (are) the source(s) of funding for the specific research (described above) that will
use these Confidential Data? (List name of funding organization, whether funds are
provided as a grant, contract, or other mechanism.)
c. Does your organization have policies regarding scientific integrity and misconduct or
human subject research that cover the secondary analysis of data? If so, please describe
these policies and provide any applicable website.
NOTE: Any required IRB approvals for your project must have been received by the time this
application may be approved.
Summary of Experience and Curriculum Vitae
6. (i) Please summarize the experience that team members at your Receiving Organization
have in using Confidential Data on other projects.
(ii) Also, please attach current curriculum vitae at the end of the Application for each
project team member listed in question 1 and question 2 above.
Security: Software, Secure Project Offices, Locations, and Computers
7. Required software. To be able to connect to the Data Portal you will need to use VMware
software. You can download and install free VMware View Client software from the
University of Michigan (UM) website. Please check with your IT group that your
organization either has VMware View Client available or will allow the download of
VMware View Client from the UM site. Please check the appropriate answer:
Your Receiving Organization has VMware View Client available for your Secure
Project Office computer(s). You will need VMware View Client version 5.3.
Your Receiving Organization will allow the download for your Secure Project Office
computer(s).
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8. Secure Project Office. Please describe the Secure Project Office location(s) and computer(s)
at your Receiving Organization using Tables 8A and 8B below.
Users cannot access data from off-site locations such as a home office. The Data Portal can
only be accessed from desktop computers within approved Secure Project Office(s). These
locations will be verified as part of a site inspection if your application is approved.
As part of the security protocol for the Data Portal, currently only computers using Windows
can be used to access the Data Portal. (If Macs are allowed in the future, you can submit a
request to modify your approved computer list to include a Mac computer.)
Note: Secure Project Office requirements are covered in the Data Portal Confidentiality
Procedures Manual. Also, in Appendix B in the Manual is a list of computer and data
security requirements and procedures that are required to be implemented as part of the
Confidential Data Use and Nondisclosure Agreement (CDUNA). A Secure Project Office
must meet all the requirements listed in the Manual and the CDUNA.
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Table 8A. Secure Project Office Location(s). List all office locations where users will access the Data Portal. Provide
exact locations including street address, building names and room numbers. (Add more rows as needed.)
Table 8A. SECURE PROJECT LOCATIONS
Location
Street Address
Building name
Room number
Please describe the overall building and the office area(s) security where the Secure
Project Office(s) are located (e.g., are employees required to swipe ID cards or show ID
upon entering the building?)
Location 1
Location 2
Location 3
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Table 8B. Computers and team member access. List all computers to be used during
the project for access to the Data Portal. (Add more rows as needed.)
NOTE:
Column 4 and last row. TEAM MEMBER ACCESS
All team members (including PPO) must be listed in Table 8B.
Access is needed. If a person will need to login in to the Data Portal (e.g., to analyze,
create, read, or review data or reports in the Data Portal) then a Secure Project Location
and computer information must be provided for the person in Table 8B so that access can
be set up to the Data Portal for that individual.
Access is not needed. If a person will not require access, then list the person in the row
labeled “Access to Data Portal is not needed for team members listed at right.”
When determining whether access is needed for a team member, keep in mind that…
All data and results remain in the Data Portal unless they have been cleared for release by
CBHSQ as the result of a disclosure review.
When an authorized team member is logged in, other project team members also in
the Secure Project Office can view results on the computer screen--but a team
member will not be able to login directly to see results unless they have their own
Data Portal user account.
You must not take notes on data or results from Confidential Data within the Data
Portal, whether handwritten or otherwise, unless that information has been cleared for
release by CBHSQ.
Column 5. IP ADDRESSES.
Every computer connecting to the Internet has a unique IP (Internet Protocol) address assigned to
it.
Your computer may connect through a fixed IP or your organization may assign an IP address
from a fixed range of IP addresses. The IP addresses listed in Table B must be provided in the
form of a public facing IP addresses. Commonly used forms of IP addresses that are not public
facing but rather are internal organizational addresses begin with “192.168.”, “172.”, or “10.”.
Please contact your IT group to verify what your public facing IP address or range of addresses
is for the computers you will use. Ask them the following questions:
1. Are you using NAT [network address translation]? If so what is the public-facing IP?
2. If not, are you using a static IP? If so, what is the static IP?
3. If not, are you using DHCP (Dynamic handling)? If so, what is the full range (subnet) for this
computer)? (However, we prefer fixed IP addresses rather than ranges. Please also ask your IT
group whether the project computers can each be assigned a fixed IP address.)
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Table 8B. COMPUTERS TO BE USED BY TEAM MEMBERS TO ACCESS DATA PORTAL
1. Secure Project
Location: (Enter the line
number from Table A.)
2. Computer
Brand, Model
Number, and
Serial Number.
(Must be a
desktop
computer.)
3. Operating
system:
enter version
of ‘Windows’
4. Team
member(s) who
will use this
computer to
login to Data
Portal
5. IP Address for computer
(or range of addresses)
ACCESS TO DATA PORTAL IS NOT
NEEDED FOR TEAM MEMBERS
LISTED AT RIGHT:
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SECTION B. Receiving Organizations
If there is only one Receiving Organization involved in this project, skip to
Section C.
If there are multiple Receiving Organizations, the Primary Contact should respond to item 9, and
send the completed version of Section B to PPOs at other Receiving Organizations, who will
then include that completed Section B version in the Application for the individual Receiving
Organization.
9. If there are multiple Receiving Organizations involved in this project, which PPO will serve
as the Primary Contact for the project overall?
Name of Primary Contact
Receiving Organization of Primary Contact
For each Receiving Organization, please list the name of the organization and the contact
information for the PPO at all the organization(s). List the Receiving Organization of the
Primary Contact first. Then please copy the table as needed and fill in the PPO contact
information for each additional Receiving Organization.
Receiving Organization(s):
Name of PPO
Title
Department (if
applicable)
Organization
Name
Organization
URL
Phone
Fax
Email
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Section C. Proposed Research Project Information
Note: If there is more than one Receiving Organization involved in a project, the content of
Section C must be identical for all Applications from Receiving Organizations involved in the
project. So the Primary Contact coordinates with all the Receiving Organizations to create the
content of Section C. The Primary Contact sends the completed Section C to PPOs at the other
Receiving Organizations so they can include it in their individual Applications for the project.
10. Title of research project.
Project title:
11. Research Project Description. Please describe the research project including the research
questions and analysis/statistical methodology to be used for the project. In your description,
please answer each item below separately labeled by item letter and topic.
If you are proposing separate, multiple research topics, you will need to describe each
research topic by answering the set of items below for each individual topic.
a) research or policy questions being addressed;
b) research plan--hypotheses, analyses, and statistical models;
c) potential significance and application of the results;
d) relevance of the research to DHHS and SAMHSA missions to reduce the impact of
substance abuse and mental illness on America's communities;
e) feasibility of the research given the data and resources available;
f) approximate sample sizes you will need for your analyses;
g) disclosure considerations and how the project will address them;
h) related experience of the PPO and project team members; and
i) relationship of past work and publications by the project team to the proposed
research
12. Time Period. What is the proposed period of time you will need access to the Data Portal for
your project? Please respond to all questions.
(i) What is the expected start date for the project?
(ii) What is the expected period of time you will need access to the Data Portal?
(iii) Do the project, and/or the start and end dates, depend on other approvals that the
Receiving Organization(s) will need (e.g., contract or grant approvals)?
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13. Software availability. While working with the Confidential Data you can only use software
that is provided within the Data Portal. Note: All the software listed below in the table is
automatically provided in the Data Portal.
a. For our information, please put an X in front of each software package you plan to
use, and put an X in second column to indicate in which format(s) you would like the
data files:
Plan Data
Software Package
to
format
Use? needed
SAS 9.3 which includes the Education Analytical Suite; SAS Enterprise
Miner Client, SAS/GIS, and SAS/SPECTRAVIEW
SPSS 19 with add-ons for (a) Regression Models and (b) Advanced Models
Stata 12
SAS-Callable SUDAAN 10.0.1
R 2.11.1
StatTransfer 9
Microsoft Office 2010 (Access, Excel, InfoPath, OneNote, PowerPoint,
Publisher, and Word).
b) If you need software that is not listed above, please describe the software (title and
version) and describe why it is needed and how it will be used:
14. Use of results. Describe how you intend to use the results of the research, including plans for
public dissemination (e.g., journal publication, conference paper presentations). Note that
results can only be publicly disseminated after they undergo a disclosure review and are
cleared for release by CBHSQ.
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Data Request
The data requested must encompass the research across all organizations involved in the project.
If there is only one Receiving Organization for the project, the PPO submits the
data request as part of the Application for Access.
If there are several PPOs (each from a different Receiving Organization) working
on the project, then the PPO listed in item 9 as the Primary Contact coordinates
the creation of an overall, combined data request for all the Receiving
Organizations.
15. Need for Confidential Data. State the reasons why the NSDUH and/or DAWN data in the
public-use data file(s) and the Restricted-use Data Access System (R-DAS) are not adequate
for conducting your research. Also, state why your research project can only be conducted
using the Confidential Data.
For those requesting NSDUH data. In addition to your reasons for needing the confidential
data, there are several birthdate and geographic variables that are not automatically provided
to approved data portal applicants. These variables are listed in Q16(ii)(b), and you can use
the table in Q16 to explain why those specific variable(s) are needed for your research.
Note: For information on the public-use files and R-DAS go to www.datafiles.samhsa.gov.
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16. Data Request for National Survey on Drug Use and Health (NSDUH)
2008-2012 NSDUH Adult Clinical Interview Data
(i)
(ii) Survey Years.
(a) Check the box for the survey years you are requesting:
2004 National Survey on Drug Use and Health
2005 National Survey on Drug Use and Health
2006 National Survey on Drug Use and Health
2007 National Survey on Drug Use and Health
2008 National Survey on Drug Use and Health
2009 National Survey on Drug Use and Health
2010 National Survey on Drug Use and Health
2011 National Survey on Drug Use and Health
2012 National Survey on Drug Use and Health
(b) Restricted variables. The NSDUH files for the Data Portal include data and variables
not in the Public Use files. The following additional variables are not automatically
provided within the Data Portal and must be requested specifically for your project.
These additional variable requests are approved by CBHSQ separately based on your
stated justification for research use.
Put an X in the first column for each variable you are requesting, and in the last
column explain why the variable is needed for your research.
X
Name of
NSDUH
Restricted
Variable
PXBMONTH
PXBDAY
Definition
Why is the variable needed for proposed
research?
Birth month of child under
18, reported by the parent
when parent and child
were both surveyed.
Birth day of child under
18, reported by the parent
when parent and child
were both surveyed.
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PXBYR
BRTHDATE
BIRMONTH
BIRDAY
BIRYEAR
EIBDATE
MTRACT
Birth year of child under
18, reported by the parent
when parent and child
were both surveyed.
Exact birthday variable,
long form string variable
format (month, day, year
Exact birth month broken
out into three numeric
variables for month, day,
and year.
Exact birth day broken out
into three numeric
variables for month, day,
and year.
Exact birth year broken
out into three numeric
variables for month, day,
and year.
An indicator variable to
show which cases have
birthday (BIRMONTH,
BIRDAY, and
BIRYEAR) edited via a
computation or randomly
assigned day based on
respondents age and the
interview date.
Majority census tract. In
other words, the census
tract that contains the
majority of the sampling
segment. In most cases,
the entire sampling
segment is entirely within
a single tract, but not all.
An indicator variable
TRACTIND
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SEGID
LAT
identifying when the
segment matches 1 tract
only, and when a segment
had to be assigned to a
tract based on the tract
containing the majority of
the segment.
Segment ID
LONG
Latitude of the centroid of
the segment.
Longitude of the centroid
of the segment.
ZIPCODE
Zipcode
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17. Survey Data Request for Drug Abuse Warning Network (DAWN). Please check each
survey year needed.
2004 Drug Abuse Warning Network
2005 Drug Abuse Warning Network
2006 Drug Abuse Warning Network
2007 Drug Abuse Warning Network
2008 Drug Abuse Warning Network
2009 Drug Abuse Warning Network
2010 Drug Abuse Warning Network
2011 Drug Abuse Warning Network
Note: Unlike NSDUH, there is not an additional set of restricted variables that you need to
request and justify why they are needed.
18. Other data. Please describe other non-CBHSQ data you plan to merge with the Confidential
Data within the Data Portal and the source of the data.
Provide an explanation for why these “external” data are necessary for the proposed research
project.
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Signature Page (Please sign in blue ink)
I attest that the information provided in this Application for Access to Confidential Data for
the project (insert project title) ______________________________________ is accurate to the
best of my knowledge:
_________________________________
Principal Project Officer (print name)
____________________________________
Principal Project Officer (signature)
____________
Date signed
Please submit original of the completed Application for Access to Confidential Data to
ICPSR/SAMHDA:
For United States Postal Service:
For Courier:
(UPS, Fed EX, DHL, etc.):
ICPSR/SAMHDA
University of Michigan
Institute for Social Research
P.O. Box 1248
Ann Arbor, MI 48106-1248
ICPSR/SAMHDA
330 Packard Street
Ann Arbor, MI 48104
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Attach Curriculum Vitae
Please attach here at the end of this Application, the current curriculum vitae for the PPO and
each project team member for your Receiving organization as listed in Section A.
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Appendix 2
Substance Abuse and Mental Health Services Administration (SAMHSA)
Center for Behavioral Health Statistics and Quality (CBHSQ)
Substance Abuse and Mental Health Data Archive (SAMHDA)
Confidential Data Use and Nondisclosure Agreement
This Confidential Data Use and Nondisclosure Agreement (“Agreement”) governs the access to
and use of Confidential Data in the Substance Abuse & Mental Health Data Archive (SAMHDA)
Data Portal under the auspices of the Substance Abuse and Mental Health Services
Administration (SAMHSA), Center for Behavioral Health Statistics and Quality (CHBSQ).
SAMHSA/CBHSQ collects data related to substance abuse and mental health under the authority
of section 505 of the Public Health Service (PHS) Act, as amended. These data are maintained
in the Substance Abuse & Mental Health Data Archive (SAMHDA). SAMHDA is maintained
by the Inter-university Consortium for Political and Social Research (ICPSR), Institute for Social
Research, University of Michigan (UM) under contract with SAMHSA.
Section 501(n) of the Public Health Service Act (42 U.S.C. 299aa(n)) (“the SAMHSA
Confidentiality Statute”) requires that data collected by SAMHSA that identify individuals or
establishments be used only for the purpose for which they were supplied.
The Confidential Information Protection and Statistical Efficiency Act (CIPSEA) of 2002
(hereinafter “CIPSEA”; see P.L. 107-347, Title V, subtitle A) establishes strong confidentiality
protections for statistical information collections. Information protected under CIPSEA must be
used only for statistical purposes.
Accordingly, any person or entity seeking permission from SAMHSA/CBHSQ to access and use
Confidential Data must sign and submit this Agreement and accompanying Nondisclosure Form
or Affidavit to SAMHSA/CBHSQ or designated representative for SAMHDA prior to the
granting of such permission.
The Principal Project Officer and Receiving Organization (collectively “data recipients/agents”)
listed below that sign and enter into this Agreement have submitted to CBHSQ an Application
for Access to Confidential Data (“Application”) to use the Confidential Data and agree to adhere
to the terms of this Confidential Data Use and Nondisclosure Agreement and its Attachments,
and applicable federal laws and regulations.
By executing this Agreement, the data recipient understands and affirms that Confidential Data
will only be used for statistical purposes consistent with the research described in the
Application, the terms of this Agreement, and applicable federal laws, regulations, and
SAMHSA/CBHSQ policies.
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I.
Requirements for Data Use
A. No Identification of Persons
The SAMHSA Confidentiality Statute prohibits the use of Confidential Data to identify
any person (including but not limited to patients and health care providers). The use of
Confidential Data to identify any person constitutes a violation of this Agreement and
may constitute a violation of the SAMHSA Confidentiality Statute and CIPSEA. This
Agreement prohibits data recipients/agents from releasing, disclosing, publishing, or
presenting any individually identifying information obtained under this Agreement.
SAMHSA and the data recipient(s)/agent(s) acknowledge that it may be possible for a
data recipient, through deliberate technical analysis of the data sets and with outside
information, to ascertain the identity of particular persons. This Agreement expressly
prohibits any attempt to identify individuals, and information that could be used to
identify individuals directly or indirectly shall not be disclosed, released, or published.
Data recipients/agents shall not attempt to contact individuals for any purpose
whatsoever, including verifying information supplied in the data set. Any questions
about the data must be referred exclusively to SAMHSA/CBHSQ.
By executing this Agreement, the data recipient/agent understands and agrees that actual
and considerable harm will ensue if he or she attempts to identify individuals. The data
recipient/agent also understands and agrees that actual and considerable harm will ensue
if he or she intentionally or negligently discloses, releases, or publishes information that
identifies individuals or can be used to identify individuals. Misuse of Confidential Data
about persons constitutes a violation of this Agreement and may constitute a violation of
the SAMHSA Confidentiality Statute and CIPSEA.
B. No Identification of Establishments
The SAMHSA Confidentiality Statute and CIPSEA prohibit the use of Confidential Data
to identify establishments (e.g.: hospital or treatment facility) unless the individual
establishment has consented. Data recipients/agents are prohibited from identifying
establishments directly or by inference in publicly disseminated material. In addition,
users of the data are prohibiting from contacting establishments for the purpose of
verifying information supplied in the data set. Any questions about the data must be
referred exclusively to SAMHSA/CBHSQ. Misuse of Confidential Data about hospitals
or any other establishment constitutes a violation of this Agreement and may constitute a
violation of the SAMHSA Confidentiality Statute and CIPSEA.
II.
Requirements of Principal Project Officers
The Principal Project Officer (PPO) must meet the following criteria:
A. Be directly employed by the Receiving Organization (i.e., the PPO cannot be a visiting
faculty member, temporary employee, contractor or outside consultant), and
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B. For institutions of higher education, must have an advanced degree (e.g., Ph.D., J.D.,
M.D. or Ed.D.).
III.
Requirements of Receiving Organization
The Receiving Organization must be an institution of higher education, a research organization,
or a government agency. The Receiving Organization headquarters, related business offices
and/or research site locations must be located in the 50 United States or District of Columbia.
IV.
Obligations of the Principal Project Officer, Research Staff, and Receiving
Organization
Confidential Data for which access is provided under this Agreement via the Data Portal shall be
limited to, and held in strictest confidence by the Principal Project Officer and Research Staff of
the Receiving Organization.
In consideration of the requirements contained in this Section of this Agreement, the Principal
Project Officer, Research Staff, and Receiving Organization agree that:
A. The Confidential Data will be used solely for statistical purposes and not for any nonstatistical purposes, as defined in section 502 of the Confidential Information Protection
and Statistical Efficiency Act of 2002 (CIPSEA).
B. The Confidential Data and any other data files used in combination with the Confidential
Data will only be viewed, accessed and analyzed for the research project that is described
in the Application.
C. The Confidential Data will only be viewed, accessed and analyzed in the approved secure
project office as listed in the Application.
D. The Confidential Data will be used to generate only statistical summary information that
does not allow any individual, family, household, or establishment to be identified, and
that no attempt will be made to identify individuals, families, households, or
establishments.
E. Where applicable, if an individual person, family, household, or establishment is
inadvertently identified in a data set or if a technique for doing so is discovered (unless
specifically the objective of the project), then:
1. No use will be made of this knowledge;
2. A summary of this identification or technique, but not including any Confidential
Data, will be reported to [email protected] immediately upon discovery
by the Principal Project Officer; and
3. This identification or technique will not be revealed to any other person.
F. When becoming aware of any suspected or actual unauthorized access, use, or disclosure
of Confidential Data, this event will be immediately reported to CBHSQ via a telephone
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call and then a follow-up report in writing as an attachment to an email to CBHSQ and
SAMHDA.
G. No attempt will be made to link this Confidential Data with any other dataset, unless
specifically identified in the approved Application for Access to Confidential Data.
H. Analyses or results derived from the Confidential Data will not be provided to any other
individual or organization without the written consent of CBHSQ. Approval for
disseminating information or results based on analysis derived from the Confidential
Data can only be obtained through CBHSQ’s disclosure review and approval process.
The scope of the disclosure review and approval process will only be for determining
compliance with CIPSEA, the Privacy Act and the Public Health Services Act, and to
ensure adherence to the confidentiality and security provisions established under this
Agreement. Notwithstanding the above, no restriction shall be placed on the ability of
the Receiving Organization to publish work or other information products (e.g.,
dissertations or theses) developed hereunder, except that such work or other information
products shall not include Confidential Data.
I. If the Receiving Organization requires a review of research proposals by an Institutional
Review Board/Human Subjects Review Committee or equivalent body, then this review
must take place and all approvals granted prior to submitting the Application for Access
to Confidential Data.
J. The Principal Project Officer certifies that all aspects of the Computer and Data Security
Requirements (Appendix B), as stated in the Attachment to this Agreement, will be
strictly followed and implemented.
K. During the period of data access, the Receiving Organization will participate in
announced and unannounced site inspection(s) conducted by CBHSQ-designated staff or
contractor during normal business hours. These site visits will inspect the physical
location and security measures in place for the use of the Data Portal and Confidential
Data along with review of relevant records pertaining to the data covered under this
Agreement.
L. The PPO will notify CBHSQ in writing, in the event the PPO plans to separate from the
Receiving Organization during the Contract Period, at least two (2) weeks prior to the last
day on the project. PPO separation from the Receiving Organization will lead to the
termination of access to the data for the PPO and Research Staff. The PPO’s separation
from the Receiving Organization terminates this Agreement, unless the Receiving
Organization identifies and obtains CBHSQ approval of a new PPO, pursuant to section
IV.M of this Agreement.
M. The Receiving Organization will obtain approval from CBHSQ prior to transferring this
Agreement to another Principal Project Officer at the same Receiving Organization. In
order to obtain such approval, the Principal Project Officer must:
1. Inform CBHSQ in writing six (6) weeks prior to the proposed date of transfer;
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2. Submit a complete copy of this Agreement signed by an official representative of
the Receiving Organization and the new PPO; and
3. Maintain responsibility for the Computer and Data Security requirements until the
transfer Agreement has been approved by CBHSQ.
N. Research Staff must be directly employed by or students currently enrolled at the
Receiving Organization (i.e., they cannot be a contractor, visiting professor, temporary
employee or outside consultant). The PPO will notify CBHSQ, in writing, of changes in
the Research Staff. Research Staff separation from the Receiving Organization will lead
to the termination of their access to the Data Portal.
O. The maximum number of persons who may have access to the Confidential Data under
this Agreement is ten (10). This includes the PPO and Research Staff combined.
P. If during the course of research there are changes in research plans or in the computer
environment that is different from (a) the information originally submitted in the
Application, (b) different from that which is required by this Agreement, and/or (c) is
different from that which in the Computer and Data Security Requirements (Appendix
B), then the Principal Project Officer shall provide CBHSQ with a copy of the revised
materials and a memorandum describing the changes. These revisions will be considered
amendments to this Agreement and may not be implemented until written approval is
obtained from CBHSQ.
Q. If the Principal Project Officer desires to extend this Agreement beyond the Contract
Period, the Principal Project Officer must submit a written request to CBHSQ three (3)
months prior to the end of the Agreement time period requesting CBHSQ approval of
such continued access. If continued access is denied by CBHSQ, then this Agreement
will terminate at the end of the Contract Period.
R. Should the Principal Project Officer, Research Staff, or Receiving Organization commit a
material breach of this Agreement that is not cured within ten (10) working days after
Principal Project Officer or Receiving Organization receives notice of such breach from
SAMHDA or CBHSQ, then CBHSQ reserves the right to terminate this Agreement. In
the event of a breach of any of the confidentiality provisions of this Agreement, CBHSQ
reserves the right to immediately terminate this Agreement. In the event of termination
of this Agreement, access to the Confidential Data and the Data Portal will be revoked.
The Principal Project Officer, Research Staff, and Receiving Organization understand
and agree that a violation of any of the terms and conditions of this Agreement may
constitute a violation of state and federal statutes, including the Confidential Information
Protection and Statistical Efficiency Act of 2002 (CIPSEA), and may subject the
Principal Project Officer, Research Staff, and/or Receiving Organization to criminal,
civil, and administrative penalties associated with violations of those statutes, in addition
to constituting a material breach of this Agreement with attendant legal liabilities.
S. The Receiving Organization will treat allegations of violations of this Agreement, by
SAMHDA or CBHSQ, as allegations of violations of the Receiving Organization’s
policies and procedures on scientific integrity and misconduct. If the allegations are
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confirmed, the Receiving Organization will treat the violations as it would violations of
the explicit terms of its policies on scientific integrity and misconduct.
V.
Miscellaneous
A. The respective rights and obligations of the Principal Project Officer, Research Staff, and
Receiving Organization pursuant to this Agreement shall survive termination of this
agreement.
B. This Agreement contains all of the terms and conditions agreed upon by the parties
regarding the subject matter of this Agreement and supersedes any prior agreements, oral
or written, and all other communications between the parties relating to such subject
matters.
C. The persons signing this Agreement have the right and legal authority to execute this
Agreement, and no further approvals are necessary to create a binding legal agreement.
D. The obligations of Principal Project Officer, Research Staff, and Receiving Organization
set forth within this Agreement may not be assigned or otherwise transferred without the
express written consent of CBHSQ.
E. Ownership of the Confidential Data will be retained by CBHSQ. Permission to use the
Confidential Data and to use the Data Portal by the Receiving Organization may be
revoked by CBHSQ through SAMHDA at any time, at CBHSQ’s discretion.
F. The Principal Project Officer and Research Staff must return MTokens to SAMHDA
upon completion of the project or when requested by CBHSQ or SAMHDA.
G. This Agreement may be amended or modified only by the mutual written consent of the
authorized representatives of CBHSQ and Receiving Organization. Both parties agree to
amend this Agreement to the extent amendment is necessary to comply with the
requirements of any applicable regulatory authority, including Federal law and policy,
and as changes in the research plan or computer environment alter the information
originally submitted as part of the Application.
H. This Agreement may be executed in one or more counterparts (facsimile transmission or
otherwise), each of which counterpart shall be deemed an original Agreement and all of
which shall constitute but one Agreement.
I. If used, the parties’ electronic signatures shall be the legally binding equivalent of a
handwritten signature.
J. Attachments incorporated into this Agreement are:
1. Appendix A: Definitions,
2. Appendix B: SAMHSA/CBHSQ Computer and Data Requirements,
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3. Appendix C: The Designation of Agent and Affidavit of Non-disclosure for the Use
of Confidential Data, or
4. Appendix D: Designation of Agent and Declaration of Nondisclosure (for Federal
employee use only).
K. The parties agree that the following documents are incorporated into this Agreement by
reference:
1. The Application for Access to Confidential Data.
2. Applicable federal laws.
VI.
Signature Page
Principal Project Officer
Signature
Receiving Organization Representative
Date
Signature
Name (type or print)
Name (type or print)
Title
Title
Organization
Organization
Building Address
Building Address
Street Address
Street Address
City, State, Zip
City, State, Zip
Date
Representative for SAMHSA\CBHSQ
Peter J. Delany, PhD, LCSW-C
RADM U.S. Public Health Service
Director, Center for Behavioral Health Statistics and Quality
Substance Abuse & Mental Health Services Administration
___________________________________________________________
CBHSQ Director Signature
Date
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Appendix A: Definitions
“Substance Abuse and Mental Health Services Administration” is a federal government agency
within the United States Department of Health and Human Services (DHHS).
http://www.samhsa.gov
“Center for Behavior Health Statistics and Quality” is a Center within the Substance Abuse and
Mental Health Services Administration, located at One Choke Cherry Rd., Rockville, Maryland,
20857. http://www.samhsa.gov/data/
“Substance Abuse & Mental Health Data Archive” is CBHSQ’s data repository. SAMHDA
houses CBHSQ public-use and restricted-use confidential databases. SAMHDA is administered
by the Inter-university Consortium for Political and Social Research (ICPSR), Institute for Social
Research, University of Michigan (UM), Ann Arbor, under contract with SAMHSA.
http://www.datafiles.samhsa.gov
“Confidential Data” refers to CBHSQ restricted-use data or individually identifiable information
that are accessible via a web portal (see Data Portal) at SAMHDA pursuant to this Agreement,
and any other external data files merged with the Confidential Data within the Data Portal. The
Confidential Data is protected under the Privacy Act of 1974 (5 U.S.C. 552a); Confidential
Information Protection and Statistical Efficiency Act (CIPSEA) of 2002 (P.L. 107-347, Title V,
subtitle A); and section 501(n) of the Public Health Services Act (42 U.S.C. 290aa(n)).
“Agent” is defined under CIPSEA as: “[A]n individual— (A)(i) who is an employee of a private
organization or a researcher affiliated with an institution of higher learning … and with whom a
contract or other agreement is executed, on a temporary basis, by an executive agency to perform
exclusively statistical activities under the control and supervision of an officer or employee of
that agency; (ii) who is working under the authority of a government entity with which a contract
or other agreement is executed by an executive agency to perform exclusively statistical
activities under the control of an officer or employee of that agency; (iii) who is a self-employed
researcher, a consultant, a contractor, or an employee of a contractor, and with whom a contract
or other agreement is executed by an executive agency to perform a statistical activity under the
control of an officer or employee of that agency; or (iv) who is a contractor or an employee of a
contractor, and who is engaged by the agency to design or maintain the systems for handling or
storage of data received under this title; and (B) who agrees in writing to comply with all
provisions of law that affect information acquired by that agency.
“Data Portal” is a virtual confidential data storage and statistical computing environment. The
Data Portal is administered by ICPSR at the University of Michigan (UM). Approved users are
provided with remote access to the Data Portal and can view and analyze confidential data using
statistical software. Users can also produce research reports and documents within the Data
Portal.
“Principal Project Officer” refers to the person who has the lead role on the project at the
Receiving Organization. This person will serve as the primary point of contact for all
communications involving this Agreement and for the Receiving Organization. The Principal
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Project Officer must be a senior staff member on the project. The Principal Project Officer
assumes all responsibility for compliance with all terms of this agreement and for the research
staff of their own organization. Under this Agreement, the PPO is a CIPSEA agent.
“Receiving Organization” refers to the organization employing the Principal Project Officer.
“Research Staff” refers to any individuals other than the Principal Project Officer with access to
the Confidential Data via the Data Portal. These persons are also known as Project Team
Members and become CIPSEA agents under this Agreement
“Representative of the Receiving Organization” is an individual that represents the Receiving
Organization and is legally authorized to enter into and sign a contract (this Agreement) on
behalf of the Receiving Organization.
“Contract Period” is the time period beginning on the date of the last signature affixed on the
signature page that executes this Agreement and ending upon completion of the research project,
as noted in the Application for Access to Confidential Data or twelve (12) months from the date
this Agreement is executed, whichever comes first.
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Appendix B: SAMHSA/CBHSQ Computer and Data Requirements
All of the following computer and data security requirements and procedures are required to be
implemented as part of this Agreement:
You must password protect the computer that is used to access the Data Portal.
Under no circumstances may you share or give your Data Portal username, password or
MToken to anyone, and this includes not sharing them with other members of your
project team or your organization’s IT staff. Passwords must not be stored on a computer
in electronic or written form. Software password storage programs may not be used.
Since the Data Portal is administered by ICPSR, University of Michigan (under contract
SAMHSA/CBHSQ), you should not contact the IT staff at your organization with
questions about the Data Portal. (You may contact your organization’s IT staff if you
need help installing the VMware client software to access the Data Portal. Your
organization’s IT staff should never be allowed to access the Data Portal or any
Confidential Data.)
Under no circumstances can any unauthorized person be allowed to access or view
Confidential Data within the Data Portal.
You must only access the Data Portal from within the authorized Secure Project Office
(as listed in the Application) using only the approved desktop computer and assigned IP
address.
Unauthorized persons are not allowed to be inside the Secure Project Office when an
authorized project team member is logged into the Data Portal.
You must not allow the computer monitor to display Data Portal content to any
unauthorized person. The computer monitor display screen must not be visible from
open doors or through windows.
You must set the computer to activate a password protected screen saver after three
minutes of inactivity.
If you are logged into the Data Portal and you leave your computer, you must
“disconnect” or “logoff” from the Data Portal. (Disconnecting from the Data Portal will
leave any open programs running, but closes the connection to the Data Portal. Logging
off of the Data Portal closes the connection and terminates all programs that are running.)
All Confidential Data must be kept within the Data Portal:
o You must not duplicate or copy the data (e.g., you must not retype and/or use nontechnical ways of copying the data, such as handwritten notes).
o You must not take screenshots, photographs, or videos of the displayed
Confidential Data or statistical outputs.
o You must not type or record the Confidential Data or results from the data onto
your PC or onto some other device or media.
You must protect all hardcopy documents related to the Confidential Data such as
research notes. Such hardcopy documents must be kept in locked drawers or cabinets
when not in use.
Prior to a disclosure review and approval by SAMHSA/CBHSQ, neither you nor any
project team member may talk about or discuss any Confidential Data or results from the
Data Portal in non-secure or public locations. These discussions cannot occur where an
unauthorized person could eavesdrop.
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You must submit all statistical outputs/results from the Data Portal to CHBSQ for a
disclosure review prior to sharing or giving such outputs to unauthorized persons. You
also agree to revise or alter such outputs as required by CBHSQ in order to minimize
disclosure risk prior to CBHSQ approving these outputs for dissemination to
unauthorized persons.
You may only disseminate aggregated information from the Confidential Data to
unauthorized persons after you obtain clearance to do so through the CBHSQ disclosure
review process.
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Substance Abuse and Mental Health Services Administration (SAMHSA)
Center for Behavioral Health Statistics and Quality (CBHSQ)
Appendix C: Confidential Data Use and Nondisclosure Agreement
Designation of Agent and Affidavit of Nondisclosure Form
I, _______________________ (print name), in consideration of access to and use of SAMHSA/CBHSQ
Confidential Data agree that:
A. I have read and will follow the requirements stated in the SAMHSA/CBHSQ Confidential Data
Use and Nondisclosure Agreement and the Confidential Data Procedures Manual for the
SAMHSA/CBHSQ Data Portal.
B. I have completed the required SAMHSA/CBHSQ confidentiality training that covered applicable
federal laws (including CIPSEA, the Public Health Service Act, and the Privacy Act), security
requirements, and disclosure review of researcher results within the last year and understand these
requirements and penalties associated with unauthorized disclosures of Confidential Data.
C. I will only use the Confidential Data obtained under the Confidential Data Use and Nondisclosure
Agreement for statistical purposes as defined by the Confidential Information Protection and
Statistical Efficiency Act of 2002 (CIPSEA).
D. I will not share, release, disclose or redistribute any Confidential Data. I further understand that I
am subject to the penalties of federal law for unauthorized disclosures of any Confidential Data.
E. I will not make any disclosures or publication of the data where a responding entity could be
identified or the data furnished by or related to any particular responding entity could be
identified.
I do solemnly swear (or affirm) that I will observe and follow all of the requirements listed above
as attested to by my signature below.
Signature ________________________________________________ Date ______________
Subscribed and sworn (or affirmed) before me this ______ day of ______________, 20__
at_____________________ (city), _________________ (state). Witness by my hand and official Seal.
_________________________________________
(Notary Public Signature)
[SEAL]
My commission expires_____________ .
Note: The penalty for unlawful disclosure of Confidential Data under this affidavit is a fine of not more than $250,000, or
imprisonment for not more than five years, or both (see P.L. 107-347, Title V, Section 513). The word "swear" may be stricken
when a person elects to affirm the affidavit rather than swear to it.
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Substance Abuse and Mental Health Services Administration (SAMHSA)
Center for Behavioral Health Statistics and Quality (CBHSQ)
Appendix D: Confidential Data Use and Nondisclosure Agreement
Designation of Agent and Declaration of Nondisclosure
for Employees of the Federal Government
I, ___________________ (print name), declare under penalty of perjury under the laws of the United
States of America that the following is true and correct.
I agree that:
A. I have read and will follow the requirements stated in the SAMHSA/CBHSQ Confidential Data
Use and Nondisclosure Agreement and the Confidential Data Procedures Manual for the
SAMHSA/CBHSQ Data Portal.
B. I have completed the required SAMHSA/CBHSQ confidentiality training that covered applicable
federal laws (including CIPSEA, the Public Health Service Act, and the Privacy Act), security
requirements, and disclosure review of researcher results within the last year and understand these
requirements and penalties associated with unauthorized disclosures of Confidential Data.
C. I will only use the Confidential Data obtained under the Confidential Data Use and Nondisclosure
Agreement for statistical purposes as defined by the Confidential Information Protection and
Statistical Efficiency Act of 2002 (CIPSEA).
D. I will not share, release, disclose or redistribute any Confidential Data. I understand that I am
subject to the penalties of federal law for unauthorized disclosures of any Confidential Data.
E. I will not make any disclosures or publication of the data where a responding entity could be
identified or the data furnished by or related to any particular responding entity could be
identified.
___________________________________
(Signature)
___________________
Date
This declaration is authorized under 28 U.S.C. 1746 as a substitute for an Affidavit of Nondisclosure as otherwise
required under the Confidential Information Protection and Statistical Efficiency Act of 2002 (CIPSEA) for access
to Confidential Data by agents of the Center for Behavioral Health Statistics and Quality (CBHSQ). Persons who
provide this Declaration are subject to penalties of unlawful disclosure of a fine of not more than $250,000, or
imprisonment for not more than five years, or both (see P.L. 107-347, Title V, Section 513).
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Appendix 3
Application Requirements
The Application for Access to Confidential Data (“Application”) requires a thorough description
of your planned research project. As you fill out your Application for Access to Confidential
Data in the Data Portal, please keep in mind the requirements that are listed below. All of these
requirements must be met for an Application to be approved. If all the requirements cannot be
met, access to the Data Portal cannot be provided.
Please take into account these requirements in the early stages of planning your research project.
This will give you sufficient time to address the requirements in your project development or
determine that the project will not be feasible at your organization or location.
For more information, refer to this Manual or to the section of the Confidential Data Use and
Nondisclosure Agreement (CDUNA) as referenced (given in parentheses).
Call for Applications
An Application for Access will only be considered if it is submitted to SAMHDA as a paper
copy with the original-signature page by the deadline of a Call for Applications. A copy of the
application as a Word document should also be emailed to SAMHDA at
dataportal@ icpsr.umich.edu.
Organizations
CBHSQ provides Confidential Data only to qualified organizations in the 50 United States
and District of Colombia. (CDUNA III)
The Receiving Organization must be an institution of higher education, a research
organization, or a government agency. (CDUNA III)
Individual researchers must apply through a recognized organization (e.g., a government
agency, university, or research institution).
No Application will be approved for a Receiving Organization that is operating within a
private residence.
Project Team
The Principal Project Officer (PPO) must be directly employed by the Receiving
Organization (i.e., the PPO cannot be a visiting faculty member, temporary employee,
contractor or outside consultant); for institutions of higher education, the PPO must have an
advanced degree (e.g., Ph.D., J.D., M.D. or Ed. D). (CDUNA II)
Research Staff must be directly employed by or students currently enrolled at the Receiving
Organization. (CDUNA II.N)
There can be no more than 10 researchers on a project, including all Receiving Organizations
involved in the project. (CDUNA IV.O).
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Multiple Receiving Organizations
Separate Applications for Access are required from each Receiving Organization involved in
a project. These Applications for Access must reference each organization and the research
project description must cover all the Receiving Organizations.
Requests for dataset(s) must encompass the research across all organizations involved in the
project.
Prior to submitting the Application for Access, the PPO must obtain IRB approval (if
required) from each Receiving Organization that requires it.
Software
The software provided for use within the Data Portal includes SAS 9.2 which includes the
Education Analytical Suite; SAS Enterprise Miner Client, SAS/GIS, and
SAS/SPECTRAVIEW; SPSS 19 with add-ons for (a) Regression Models and (b) Advanced
Models; Stata/SE 11; SUDAAN 10.0.1 (SAS-callable library); StatTransfer 9, R 2.11.1, and
Microsoft Office 2010 (Access, Excel, InfoPath, OneNote, PowerPoint, Publisher, and
Word).
If you need other software, contact SAMHDA ([email protected]) to check if the
additional software can be provided and, if so, include this information in your Application.
Computers
Only desktop computers can be used to access the Data Portal.
Only Windows computers can be used to access the Data Portal. Mac computers could not be
used at this time.
Security Requirements
VMware Client software must be installed on the desktop computers in Secure Project
Office(s) for connection to the Data Portal. (The software can be downloaded from the
University of Michigan ITS website.) Please confirm with your IT group that installing
VMware will be allowed by your organization.
The Secure Project Office(s) is the only place from which the Data Portal may be accessed.
Make sure your organization has such space available. (Manual Section 3, CDUNA IV.c)
Applicants must confirm that their computers and Secure Project Offices meet the physical
security requirements for computer set-up and locations as required in the Application and
Agreement. (Appendix 2, CDUNA Appendix B)
All researchers must follow all security requirements covered in this Manual and the
Confidential Data Use and Nondisclosure Agreement. (CDUNA Appendix B)
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File Type | application/pdf |
Author | DHHS |
File Modified | 2015-01-07 |
File Created | 2013-09-18 |