Data Requirements for Compliance with the Human Tissue Act and Biobanking

Cheryl Gillett King’s College London

Human Tissue Act 2004

Section 53: Powers of inspection, entry, search and seizure*Schedule 6 (which makes provision about powers of inspection, entry, searchand seizure for the purposes of this Act) has effect.

Schedule 6 Part 1: Inspection of statutory records(1) A duly authorised person may require a person to produce for inspection any records which he is required to keep by, or by virtue of, this Act.

(2) Where records which a person is so required to keep are stored in any electronic form, the power under sub-paragraph (1) includes power to require the records to be made available for inspection—(a) in a visible and legible form, or(b) in a form from which they can readily be produced in a visible and legible form.

(3) A duly authorised person may inspect and take copies of any records produced for inspection in pursuance of a requirement under this paragraph.

*A duly authorised person may at any reasonable time enter and inspect any premises in respect of which a licence is in force.

Human Tissue Authority Data-Associated Standards

Participant• A coding and records system facilitates traceability of bodies, body parts, tissues and

cells, ensuring a robust audit trail (GQ6) .• The reasons for disposal and the methods used are carefully documented (D2).• Equipment is appropriate for use, maintained, quality assured, validated and where

appropriate monitored (PFE5) Staff• Staff involved in seeking consent receive training and support in the implications and

essential requirements of taking consent (C3).• Staff are appropriately qualified and trained in techniques relevant to their work and

are continuously updating their skills (GQ3). Documents• There is a documented system of quality management and audit (GQ2).• There is a systematic and planned approach to the management of records (GQ4)• There are documented procedures for distribution of bodies, body parts, tissues or

cells (GQ5)

Human Tissue Authority data-associated standards apply to both study-specific collections and biobanks

that come under a HTA licence

What is a Biobank?

• Biobanks collect biological samples and data from donors for a general research purpose rather than a specific study.

• As the exact use of the samples/data at the time of collection is unknown, donors may consent to different types of research use.

• Biobanks must have a HTA licence and Research Ethics Committee approval to collect and distribute material and data

• Biobanks are long-term facilities where samples may be used to exhaustion for multiple studies and data used indefinitely.

Any cells or tissue obtained during my diagnosis, surgery and any subsequent procedures may be kept for future research. Including samples left over from previous diagnostic tests

These samples may be used for genetic research

These samples may be used for research involving animals

These samples may be used to create cell lines

Specific individuals contracted to GSTT may look at relevant sections of my medical notes to obtain information about my condition.

My samples and data will be stored and used anonymously.

My GP can be contacted for information relevant to my condition and ongoing treatment in the event that I stop attending GSTT.

Surplus Tissue Consent

Research Specific Tissue Consent

Extra tissue samples being taken for research purposes at the time of my planned diagnostic biopsy or procedure (up to 4 extra cores)

Extra tissue samples being taken for research purposes during treatment and understand that this will involve an extra biopsy procedure (up to 4 extra cores)

Donate blood for research purposes (20mL or approximately 4 teaspoons).

Provide a urine sample (Urology biobank only)

The use of my donated samples for genetic research

The use of my donated samples for research involving animals

The use of my donated samples to create cell lines

The use of my anonymised clinical details together with my donated samples. I am aware that no research information can be linked back to me

Data Collection Example from KHP Breast Biobank

Biobank DatabaseTrust Pathology

Database

Trust Patient Record

Trust Cancer Information

System

Sample Format

Sample Storage Location

Collection Times

Researcher Requests• Sample/Data supplied• Data generated

GP/ Cancer Registry

Legacy research data

Research Clinical Database

Pseodoanonymisation

Clinical Genetic Services

Consent

PROBLEMS - Dealing with historical consent forms!

2001 v1: “I agree that tissue removed from my breast during my operation may be used for future research, which may contribute to a better understanding of the causes and treatment of breast disease”(REC 01/03/09)

2001 v2: “I agree that a small amount of my breast tissue may be used for research that will contribute to our knowledge and understanding of breast disease” (REC 01/03/09)

2006 Surplus Tissue: Tiered consent• Read and understood PIS• Agree to current and future surplus tissue use for research• Agree to blood being taken• Agree to GP/ Cancer Registry being contacted• Agree to Clinical data being used, pseudoanonymisation and no access

to research results• Understand can revoke consent (REC 06/Q0704/155)

PROBLEMS - Dealing with historical consent forms!

2007 Surplus Tissue: Tiered consent• Read and understood PIS• Agree to current and future surplus tissue use for research• Agree to blood being taken• Agree to genetic research• Agree to access to medical records• Agree to GP/ Cancer Registry being contacted• Agree to Clinical data being used, pseudoanonymisation and no access

to research results• Understand can revoke consent (REC 07/H0804/131)

PROBLEMS - Dealing with historical consent forms!

2012 Surplus Tissue Form: Tiered consent• Agree to past, current and future surplus tissue use for research• Agree to genetic research• Agree to use in research involving animals• Agree to creation of cell lines• Agree to access to medical records• Agree to GP being contacted• Agree to pseudoanonymisation• Understand can revoke consent (REC 12/EE/0493)

2012 Research-Specific Tissue Form: Tiered consent• Extra tissue samples during diagnostic procedure• Extra tissue samples requiring extra biopsy procedure• Agree to donate blood• Agree to provide urine sample• Agree to genetic research• Agree to use in research involving animals• Agree to pseudoanonymisation• Understand can revoke consent (REC 12/EE/0493)

Dealing with historical consent forms

Patient Asked?

Date

Not AskedYesRefusedPre-Consent- Not AskedPre-Consent - Asked

Tissue Research UseBlood Research UseGenetic Research UseMedical Records AccessGP/Registry AccessClinical Data Research UseResearch AnimalsCreation of Cell LinesRetrospective TissueResearch Tissue OnlyUrine

YesNoNo ResponseNot Applicable

Harmonising and Benchmarking of BiobanksNational Cancer Research Institute's (NCRI) Confederation of Cancer Biobanks

Two related standards, for quality management and data

Quality standard: Covers the management of quality in a biobank and provides basis of planned accreditation scheme.

Data standard: Shows the data needed to support effectivecommunication about biobanks and the samples they are able to provide.

http://www2.ncri.org.uk/ccb/bestpractice.html

Quality Standard

Section 32: Handling data

32.1 DataCompliance with legislation

32.2 Data protectionData protection documents to be reviewed by suitably qualified person

32.3 Data securityControlling access to biobank data, recovery plan, transfer policy

32.4 Data qualityAssurance of validity, completeness, consistency, coverage, accuracy, timeliness, communications

Section 33: Return of research data to the biobankPolicy on the return of research data to the biobank

Standardisation of Data between Biobanks

• MIABIS: Minimum Information About BIobank data SharingBBMRI (Biobanking and Biomolecular Resources Research Infrastructure)

• STRATUM: Strategic Tissue Repository Alliances Through Unified Methods project

UK Consortia of commercial and academic stakeholders

• SPREC: Standard Preanalytical Coding for Biospecimens: Defining the Sample PREanalytical Code

International Society for Biological and Environmental Repositories (ISBER)

• BRISQ: Biospecimen reporting for improved study quality.NCI Biospecimen Research Network

• Biobank Data Standard: Collecting, storing and sharing data describing human biological material for research

NCRI Confederation of Cancer Biobanks

NCRI/CCB Biobank Data Standard:

“The data standard, built around existing standards, is intended to support effective data sharing and communications between research groups, organisations and consortia, and has already been adopted by some. It is intended to be compatible with the creation of a single central data portal for UK-based biobanks to facilitate the identification of and access to samples for research”.

In Biopreservation and Biobanking

Data Elements Required of All BiobanksBiobank, Diagnoses, Organs, Available data

Data Required to Meet the Minimum StandardCollection, Sample data, Collection to available data

Data Required to Meet the Best Practice StandardPatient, Patient diagnosis, Sample group, Solid specimen, Tissue sample,Fluid sample, Sample to available data

For each data field there must be:Field Name Format Description Source

NCRI/CCB Biobank Data Standard:

http://ccb.ncri.org.uk/wp-content/uploads/2014/03/CCB-Data-Standard-v1.pdf

And Finally……

Progress on a Combined Surgical and Research Consent Form Initaitive

• Piloted combined form for patients with breast disease

• Feedback from both patients and clinicians

• Agreement in principle from GSTT TRaQ

• Pending NHS REC approval for modified information leaflet and consent statements

Aim to seek consent from all GSTT patients for their surplus surgical tissue to be used for a broad range of research studies