Paper by S. Kalkman et al: “The sharing of clinical research data is increasingly viewed as a moral duty . Particularly in the context of making clinical trial data widely available, editors of international medical journals have labeled data sharing a highly efficient way to advance scientific knowledge [2,3,4]. The combination of even larger datasets into so-called “Big Data” is considered to offer even greater benefits for science, medicine and society . Several international consortia have now promised to build grand-scale, Big Data-driven translational research platforms to generate better scientific evidence regarding disease etiology, diagnosis, treatment and prognosis across various disease areas [6,7,8].
Despite anticipated benefits, large-scale sharing of health data is charged with ethical questions. Stakeholders have been urged to consider how to manage privacy and confidentiality issues, ensure valid informed consent, and determine who gets to decide about data access . More fundamentally, new data sharing activities prompt questions about social justice and public trust . To balance potential benefits and ethical considerations, data sharing platforms require guidance for the processes of interaction and decision-making. In the European Union (EU), legal norms specified for the sharing of personal data for health research, most notably those set out in the General Data Protection Regulation (GDPR) (EU 2016/679), remain open to interpretation and offer limited practical guidance to researchers [12,12,13]. Striking in this regard is that the GDPR itself stresses the importance of adherence to ethical standards, when broad consent is put forward as a legal basis for the processing of personal data. For example, Recital 33 of the GDPR states that data subjects should be allowed to give “consent to certain areas of scientific research when in keeping with recognised ethical standards for scientific research” . In fact, the GDPR actually encourages data controllers to establish self-regulating mechanisms, such as a code of conduct. To foster responsible and sustainable data sharing in translational research platforms, ethical guidance and governance is therefore necessary. Here, we define governance as ‘the processes of interaction and decision-making among the different stakeholders that are involved in a collective problem that lead to the creation, reinforcement, or reproduction of social norms and institutions’…(More)”.