MRCT Center - Wellcome Trust Mee2ng on The Future of Clinical Trial Data Sharing
Monday 21 March 2016
MRCT Center - Wellcome Trust Mee2ng on The Future of Clinical Trial - - PowerPoint PPT Presentation
MRCT Center - Wellcome Trust Mee2ng on The Future of Clinical Trial Data Sharing Monday 21 March 2016 Please Note the Following: This mee2ng is being recorded for internal purposes: o If you choose to par2cipate in a discussion, you are
Monday 21 March 2016
to consent to the use of your comments in these recordings
promo2onal materials, including the MRCT Center website and newsleJer
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Presenter: Nicola Perrin, Wellcome Trust
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What might a future model look like?
REPOSITORY
FEDERATED PORTAL DATA IN DATA OUT
What might a future model look like?
REPOSITORY
FEDERATED PORTAL DATA IN DATA OUT What data, from where? What is the access model?
Open access / reviewed access / stricter controls
Can data be downloaded? Who operates this? What is the governance model? Who pays?
Is data deposited, or kept by the data generator until requested?
Is there some resource to help with curation and de-identification? How does an IRP operate?
Proposed Model PlaUorm - straw man
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Central mul2- stakeholder governance
Central repository for academics (or
not wish to “host” data Provides shared services for:
researcher requests
PORTAL: Central user interface portal with search engine building upon exis2ng search engines (e.g. ClinicalTrials.gov and ICTRP) to pull informa2on from registries / provide complete and robust “denominator” of exis2ng data PLATFORM: federated plaUorm model with op2onal central component enabling access to data, combining datasets and allowing downloading as appropriate
Sponsor A Data sets
Repository B (other data sets)
Researcher Researcher
Perform Feasibility checks
Presenters: Barbara Bierer, MRCT Center Fergus Sweeney, European Medicines Agency
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The Importance of Data Sharing and Transparency
MRCT CENTRE – Wellcome Trust meeting The Future of Clinical Trial Data Sharing
Fergus Sweeney, EMA Head of Division, Inspections and Human Medicines Pharmacovigilance
Our Mission
The mission of the European Medicines Agency is to foster scientific excellence in the evaluation and supervision of medicines, for the benefit of public and animal health.
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EMA is designed to coordinate and mobilise the existing scientific resources of Member States:
European experts’ network underpins the work of the CHMP, CVMP, COMP, PDCO, CAT, PRAC, HMPC, working parties, SAGs
EMA: A Networking Agency
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The Agency is responsible for:
applications submitted by pharmaceutical companies
evaluates to patients and healthcare providers
The various roles of the EMA
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28 EU + 3 EEA Member States + 4,500 European experts EU institutions: Commission - Parliament Committee for Orphan Medicinal Products (COMP) Committee for Herbal Medicinal Products (HMPC)
EMA Secretariat
Committee for Veterinary Medicinal Products (CVMP)
Management Board
Committee for Human Medicinal Products (CHMP) Committee for Advanced Therapies (CAT) Paediatric Committee (PDCO)
EMA-EU Network
Pharmacovigilance Risk Assessment Committee (PRAC)
Transparency – some history:
§ EPAR (1995); Same SPC and PIL in all languages (1995); Publication of all experts (1996); Summaries of opinions (1998, 2002); Rules on access to documents (1997, 2006); Orphan drug INN and orphan indication (2004); PIP opinions (2006)
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Examples of key transparency initiatives
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…and more examples
recordings available
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Access to documents, requests for information
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implementation
impact on Agency operations
information each month
requester…..although they may share, it is less visible
Clinical trial transparency and EMA – 3 pillars
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EU Clinical Trials Register Proactive publication of clinical study reports – Policy 70 Clinical Trial Regulation and EU Portal and Database – public information clinical trials authorized in EU
Objectives of clinical trial transparency
similar trials?
innovation capacity of European medical research.
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EU Clinical Trials Register Proactive publication of clinical study reports – Policy 70 Clinical Trial Regulation and EU Portal and Database – public information clinical trials authorized in EU
EU Clinical Trials Register
– Phase II-III-IV trials conducted in adults in the EEA – Phase I-II-III-IV paediatric trials in the EEA – Only phase I trials conducted in adults & part of a PIP are made public (small %) – NCA decision positive and IEC opinion positive recorded in EudraCT for adult trials – for paediatric trials IEC opinion positive or negative – Paediatric CT outside of the EEA if they are part of an agreed Paediatric Investigation Plan (PIP) (including a small % of adult phase I trials if they are part of a PIP)
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EU Clinical Trials Register Proactive publication of clinical study reports – Policy 70 Clinical Trial Regulation and EU Portal and Database – public information clinical trials authorized in EU
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Chapter 1 Scope and definitions Chapter 2 Procedural guidance and processes on submission Chapter 3 Guidance on anonymization of clinical study reports for publication Chapter 4 Guidance on what is no considered to be CCI, and on redaction in the limited circumstances where information can be considered CCI.
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– Any new MAAs and Article 58 applications, submitted after January 2015 – Extension of indication applications and line extension applications for existing CAPs, submitted after 1 July 2015 – All other post-authorisation applications for existing CAPs submitted as of a date TBD in 2016
– Clinical data: clinical reports (i.e. clinical overviews (module 2.5), clinical summaries (module 2.7) and clinical study reports - CSRs (module 5), together with appendices 16.1.1, 16.1.2 and 16.1.9) and individual patient data (IPD)
this afternoon’s session.
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Policy 70 on proactive publication of clinical data submitted under centralised procedure in MAAs to EMA
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EU Clinical Trials Register Proactive publication of clinical study reports – Policy 70 Clinical Trial Regulation and EU Portal and Database
Scope of clinical trial Regulation (EU) No. 536/2014
investigator site in EU/EEA)
into application
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Member States Sponsors EMA
General public
Commission Applicant of a MA
Submit submission package (CTA & dossier) / Address request for information Submit notifications:
Global)
affect risk/benefit Submission of clinical study result summary Submission of Inspection Reports
Update of Clinical Trial information re non substantial modifications Submission of CSR Submission of Union Control Reports Notification of willingness to be RMS(Part 1)/Decision on RMS Submission of requests for information Notification of the final validation (initial, additional MS or Substantial Modification) Submission final AR Part 1 and 2 Final single decision notification Communication disagreement to part 1 assessment Communication on implementation
Submission Inspection Information This slide depicts the processes each stakeholder will be able to complete in the new EU Portal and Database:
Search and view CT related information saved in the EU database (that is not confidential) Runs the system and generates reports on the data in the system
Processes for each stakeholders in the system
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EU portal and database – Data standardisation
WHO
WHO ICTRP standard will be fully met, and data provided to the ICTRP by the EU database
NIH
(clinicaltrials.gov)
Collaboration and discussion on the anticipated changes to the data model (focusing on protocol / results) to ensure convergence and alignment where the same elements are used in both US and EU systems
CDISC
Collaboration on clinical trial registration including study design data model, and in due course on results model
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Transparency legal requirements: Clinical Trials Regulation
Article 81(4) of Regulation (EU) No. 536/2014
grounds:
– Protection of personal data; – Protection of commercially confidential information in particular taking into account the MA status of the medicinal product, unless there is an overriding public interest in disclosure; – Protecting confidential communication between MS in relation to the preparation of the assessment report; – Ensuring effective supervision of the conduct of a clinical trial MSs.
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“Functional specifications for the EU portal and EU database to be audited - EMA/42176/2014”
Management Board and published on 6 October 2015
http://www.ema.europa.eu/docs/en_GB/ document_library/Other/2015/10/ WC500195084.pdf
Requirements for operation of a feasible system
Article 81(4), are required.
particular data element or document should be made public.
taking place in the system every year.
data and documents and those viewing them know what will be made public and when.
an overriding public interest applies, or to remediate a publication error.
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Summary of rules
group or other type of organisation.
clinical trial application:
– Category One: Pharmaceutical development trials– essentially Phase I trials in healthy or patient volunteers, bio-equivalence and bio-similarity trials. – Category Two: Therapeutic exploratory and confirmatory trials - essentially Phase II and III trials of novel products or new indications or formulations of existing products – Category Three: Therapeutic use trials – essentially Phase IV and low-intervention trials
certain data and documents up to a maximum time limit, if needed, to protect commercially confidential information.
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Summary of Rules
wish to participate in trials with therapeutic, diagnostic or preventive objectives.
Marketing Authorisation Application in the EU the clinical study report).
after the end of each trial, regardless of the Marketing Authorisation status of the medicines studied in the trial.
maximum of 30 months post end of trial (i.e. maximum 18 months deferral).
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Summary - Clinical Trial Transparency – and EMA
– Growing body of clinical trial information and results summaries in EU Clinical Trial Register for trials authorised since 2004. – New clinical trial Regulation - Extensive information on clinical trials from authorisation to the trial summary results of all trials authorised in EU/EEA under the new Regulation.
– All clinical study reports included in marketing applications to EMA from 1 Jan 2015 on – Clinical study reports for all trials authorised in EU/EEA under the new clinical trial Regulation and included in a marketing application in EU.
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Thank you for your attention
European Medicines Agency
30 Churchill Place • Canary Wharf • London E14 5EU • United Kingdom
Telephone +44 (0)20 3660 6000 Facsimile +44 (0)20 3660 5555 Send a question via our website www.ema.europa.eu/contact
Fergus.Sweeney@ema.europa.eu Further information
Follow us on @EMA_News
Public data and information about medicines, their development and authorisation
Rebecca Li, PhD Moderator: Barbara Bierer, MD
March 21, 2016
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MRCT Governance Working Group
Informa2on Technology (IT) Working Group Business Models Working Group
Data Sharing Strategy Phase: Governance
4/5/16
Develop a high-level charter Develop principles for organiza4onal leadership
Strategic policy decisions
Workgroup Deliverables
– Governance structure – Review Process – PlaUorm par2cipa2ng trials – Data packages – Data Sharing guidance and resource kit
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Proposed Organiza2onal Structure for Non Profit Vivli
Board of Directors Finance & Audit CommiJees Advisory Technical CommiJee External Advisory CommiJee President / Exec Director
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Proposed Governance Model: Hybrid
– Incorporated as Non-profit Organiza2on – Membership of the Board is combina2on of representa2on of contributors to the organiza2on (ojen financial) and “at-large” posi2ons – Representa2ves can be nominated by a contributor, subject to approval of the board (ojen termina2ng when organiza2on is financially stable and independent) – At-large members, appointed by the nomina2ng commiJee of the Board (ajer ini2al appointment) according to personal investment in the project, e.g:
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Workgroup Deliverables
– Governance structure – Review Process – PlaUorm par2cipa2ng trials and data packages – Data Sharing guidance and resource kit
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Review Process Proposal
Vivli will act as a “data library” which respects the needs of requesters and concerns of donors Several review op2ons for shared data were developed:
require a review process.
selected IRP.
PlaUorm will forward requests for review.
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Data Request Model: Phase 1
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Data Request Models: Aspira2onal
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Workgroup Deliverables
– Governance structure – Review Process – PlaForm parHcipaHng trials and data packages – Data Sharing guidance and resource kit
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Par2cipa2ng Trials and Par2cipants
– Registered in ClinicalTrials.gov, WHO ICTRP or other trial register – Metadata (searchable terms) for par2cipa2ng trials are available and curated – IPD is or will be made available
that will be included and where appropriate link to exis2ng guidance and regula2ons.
large pivotal trials of marketed products
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250 trials
Sponsor no,fies pla0orm of # of par,cipa,ng trials
PlaUorm curates metadata for the 250 trials IPD SHARED
Searchable terms match available IPD Review process
PlaUorm Par2cipa2ng Trials (e.g. Publica2on-based)
prepared for submission
Submission to Journal
Prepared for PlaUorm (anonymized)
Submission to PlaUorm
Package and Publica2on held in Embargo
Ar2cle Published & Data available
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Data Packages – What to share?
materials about a study that is to be shared via the PlaUorm
May include:
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Data Packages – Recommenda2ons
Basic Package (recommended for inclusion)
May also be included if available to share:
A checklist will be available by the pla0orm to provide op,ons
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Workgroup Deliverables
– Governance structure – Review Process – PlaUorm par2cipa2ng trials and data packages – Data Sharing guidance and resource kit
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Data Sharing Resource Kit (See Appendices)
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Successful Case Studies of Secondary Use of Data
Data Generator
Data Recipient
Impact
(1) ITN Network – RAVE Trial – NIAID (funder)
Inves2gators at the Ins2tute for Computa2onal Health Sciences, University
Reanalysis of the RAVE trial demonstrated a correla2on between pa2ent’s granulocyte subsets at baseline with the likelihood of remission at 6 months following either cyclophosphamide or rituximab in pa2ents with ANCA- Associated Vasculi2s.
(2) Pfizer, GSK, Lundbeck
Inves2gators at the University of Gothenberg, Sweden, Swedish Research Council (funder)
In a post-hoc analyses of 18 trials of SSRIs u2lizing a single ra2ng scale versus the Hamilton depression ra2ng scale, SSRIs were shown to be more consistently effec2ve than placebo in the treatment of pa2ents with major depression.
(3) Medtronic – YALE YODA (intermediary)
Inves2gators at the University of Colorado Department of Orthopedics
Metaanalysis of 4 trials demonstrated that, for pa2ents with degenera2ve disc disease following lumbar arthrodesis, the presence of radiographic fusion was correlated with improved clinical outcomes compared to radiographic non-union (Oswestry Disability Index - ODI; Numeric Ra2ng Scales (NRS) for back and leg pain).
(4) J&J, Amgen, Hoffman-LaRoche and 5 independent inves2gators
Inves2gators at University of Bern; German Federal Ministry of Educa2on and Research, Medical Faculty of University of Cologne and Oncosuisse (funder)
Metaanalysis of 18 trials (13,933 pa2ents) demonstrated that administra2on of erythropoiesis-s2mula2ng agents in oncology pa2ents increased mortality compared with transfusion therapy alone. The increase in mortality must be balanced against the poten2al benefits of erythropoiesis -s2mula2ng agents in this pa2ent popula2on.
(5) Pfizer, Sanofi
Inves2gators at University of North Carolina
Mitoxantrone added to prednisone in the treatment of pa2ents with post-docetaxel, metasta2c, castrate-resistant prostate cancer showed no survival benefit over the use of prednisone alone and may be associated with increased toxicity.
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The MRCT Center’s Data Sharing Workgroup Members
4/5/16
Governance Work Stream
Co-Chairs: MRCT Center Wellcome Trust Arnold FoundaHon
Team Members: Mark Barnes (MRCT Center) Barbara Bierer (MRCT Center) Kris Bolt (MRCT Center) Stuart Buck (Laura and John Arnold FoundaHon) Marla Jo Brickman (Pfizer) Nina Hill (Pfizer) Lauren Johnson (MRCT Center) Rebecca Li (MRCT Center) Nick Lingler (DeloiSe ConsulHng) Heather Marino (MRCT Center) Sandra Morris (Johnson & Johnson) Jennifer O’Callaghan (Wellcome Trust) Nicola Perrin (Wellcome Trust) Paul Seligman (Amgen) Ida Sim (UCSF) Jessica ScoJ (GlaxoSmithKline) Catrin Tudur Smith (U. of Liverpool) Natalie Zaidman (Pfizer)
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Ques2ons and Discussion
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Presenter: Rohin Rajan, DeloiJe Consul2ng LLC Moderator: Frank Rockhold, Duke University
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MRCT Clinical Trial Data Sharing Business Model Working Group Outputs
March 2016
Executive Summary
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Key objectives for the Wellcome Trust / MRCT Business Models workstream
1) To develop sustainable business models for Vivli 2) To align with the governance and IT workgroups on how to best to develop and capacitate the not-for-profit entity, including in regard to its financial viability
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Framework and Approach
Platform = interconnected or consolidated system for data cataloguing, housing and sharing System = IT infrastructure to support utilization of the platform Entity = future organization to manage the platform and systemsProposals discussed in the Business Models workstream need to be aligned to IT and Governance workstreams to finalize operating model and timeline
What we did Why we did it Performed an externalscan of existing clinical trial data sharing technologies and platforms
Defining high-levelfunctionality and capabilities of the desired platform / system / entity
Determine existingmarket capabilities, gaps and short-term needs; validate scope
the development of Vivli’s business model
Define potentialwould enable the capabilities required for Vivli
Determine optimalexecution modes based on cost, speed, risk, revenue streams Determine near-term and long-term
evolve Vivli
Develop a viable andsustainable business model to address gaps, seek out potential partners, and build as needed
Landscape Capabilities Operating Model Timeline
Context Discussion
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Assumptions and considerations
§ Should be a “not-for-profit” organization, but can collaborate with for and non-profit companies § Requires sustainable support (resources, funding) from industry, academics and other stakeholders § Over the next 18 – 36 months, the objective is to create valuable offerings to attract users and define
§ Cannot reinvent technologies already in place; but in the near-term, potentially:
– Connect existing platforms in an extensible and collaborative manner – Improve interoperability by facilitating data warehousing, integration, and curation – Create a marketplace for academic researchers and smaller, non-participating companies
§ Revenue opportunities will be evaluated continuously as offerings become mature § Long-term, Vivli may be able to unify various data sources into a single multifaceted platform
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Key findings from the external scan
§ The scan revealed that numerous initiatives either exist or have been created § No single effort has become the ‘silver bullet’ § Several major biopharmaceutical companies are involved in at least two data sharing initiatives § Smaller players and academics do not have similar modes for sharing clinical trial data
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Objectives for today’s Business Model presentation
§ Consider and discuss the various operating models presented; determine if other, distinct models exist § Review and align on near, mid and longer-term options for the evolution of Vivli § Discuss and determine which functional capabilities can be achieved through (post presentations):
– Partnerships with existing systems or platforms – Assembly and coordination of current marketplace offerings – Creation / development of unique services and capabilities
Executive Summary
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Potential data sharing operating models
A number of different routes could be taken to achieve the goal of increasing clinical trial data sharing & creating a data aggregation platform
Engage in advocacy for policy and practical changes to increase transparency and cooperation in clinical trial data sharing with existing efforts (platforms / systems / regulators, other stakeholders) Advocate & Lobby Build and develop capabilities as needed to facilitate the exchange of clinical trial data Build & Develop Find, support, and functionalize specific solutions to address existing and emerging gaps in clinical trial data sharing, to facilitate exchange between platforms Assemble Identify and partner with existing initiatives (e.g. Project Data Sphere, CSDR) to enable immediate access to current capabilities / functionality as a foundation for growth Partner § Generalized options to be aligned to specific IT and Governance goals and partnership opportunities § Options not mutually exclusive, and could be reconfigured to meet evolving needs § “Advocate and Lobby” model would continue throughout the evolution of Vivli § “Advocate and Lobby” option does not comprise a data sharing entity, and could be an extension of MRCTs
Assumptions
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Operating model dimensions
Operating models were evaluated using a set of comparison dimensions
Capability • Technological capabilities offered by Vivli to facilitate data sharing across multiple stakeholders Dynamism
Investment
Stakeholder Risk
sponsor’s drug leading to regulatory action and / or revenue losses
associated implications on users reputation and credibility
inability to sustain profits over the long term; also risk of competition to existing entities / Vivli depending
Control
Time to build • Speed with which the solution can be implemented / achieved Build / Develop Partner Advocate & Lobby Assemble
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Advocate & Lobby
Engage in advocacy, lobbying for policy and practical changes to increase transparency and cooperation in clinical trial data sharing with existing efforts (platforms / systems / regulators and other stakeholders)
Ranking Detail
Capability
Dynamism
sharing, and influence the broader environment Investment
Stakeholder Risk
address the needs of stakeholders leaving Vivli with reputational consequences Control
Time to build
Build / Develop Partner Advocate & Lobby Assemble
Less Favorable More Favorable
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Assemble
Ranking Detail
Capability
that facilitate sharing by addressing current gaps Dynamism
trends in clinical trial data sharing, and to find / fund evolving solutions Investment
Stakeholder Risk
party solutions and driving value
Control
party, but control achieved through customization and coordination Time to build
technologies, but still may take time to derive and build solution Build / Develop Partner Advocate & Lobby Assemble
Neutral
Less Favorable More Favorable
Find, support, and functionalize specific solutions to address existing and emerging gaps in clinical trial data sharing, to facilitate exchange between platforms
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Partner
Ranking Detail
Capability
conducted as needed (including to achieve interoperability) Dynamism
limited to capabilities offered by the platform / system Investment
(depending on level of upgrade targeted)
Stakeholder Risk
needs Control
for customization Time to build
enhancements Build / Develop Partner Advocate & Lobby Assemble
Neutral
Less Favorable More Favorable
Identify and partner with existing initiatives to enable immediate access to current capabilities / functionality as a foundation for growth
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Build / Develop
Ranking Detail
Capability
gaps, best practices from existing solutions, and stakeholder needs Dynamism
Investment
technological solution Stakeholder Risk
Control
Time to build
deploy solutions over a faster timeline Build / Develop Partner Advocate & Lobby Assemble
Less Favorable More Favorable
Build and develop capabilities as needed to facilitate the exchange of clinical trial data
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Comparison across dimensions
Capability Dynamism Investment Stakeholder Risk Control Time to build Cumulative
Dimension Rankings
Build / Develop Partner Advocate & Lobby Assemble
(N) (N)
Less Favorable More Favorable
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Learnings from the operating model comparison
§ The “Build” option offers greatest control
– “Partner” & “Assemble” models could achieve similar capabilities more flexibly, faster and at lower cost – “Partner” offers established capabilities and contain the largest data-sets – Certain unique capabilities may require build as they are currently unavailable not suitable in current form (e.g. due to cost, capabilities, content etc.) - to be discussed post IT presentation
§ The “Advocate and Lobby” option is the lowest investment and could be an extension of MRCT
– Offers no technological capabilities in the near-term, but serves to align other initiatives and grow users – As a lobbying entity, can influence the key technology, service and regulatory priorities
Executive Summary
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Proposed timeline for the evolution of Vivli
Near-term (0 – 6 mos) Mid-term (6 – 18 mos) Long-term (18 - 36+ mos) Advocate & Lobby
Determine viability of next step§ Clearly define mission, scope, and timeline for Vivli § Widespread awareness and buy in to Vivli’s mission amongst the broader industry stakeholders (academics, regulators/ editors etc.) § Service offerings and revenue targets identified Partner Assemble § Agreements / partnerships achieved with other data sharing
§ Clearly defined scope / roles and responsibilities between Vivli and complementary organizations § If possible Vivli will endeavor to not be in “addition to” existing platforms but will assume their role/ services to reduce burden § Participation / sign on by biotechs & academic organizations Build / Develop (as needed) § Substantial and growing user base § Technological capabilities established to facilitate data sharing § Sufficient revenue flow to sustain
achieved
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Timeline Details: Near-term – 0 to 6 months
0 – 6 Months 6 – 18 Months 18 – 36+ Months Key Considerations / Requirements Investment Required (annualized)
§ Screen potential targets for partnership / assembly; conduct capability gap analysis § Achieve partnership with a major data sharing platform § Identify required investment level, revenue sources, and
§ Determine scope of Vivli – Type of companies / willingness to participate – Type of capabilities targeted (technology, services) – Scope / type of data to be shared § Align with ongoing industry data sharing platform / effort § Establish a clear value proposition for Vivli § Create a detailed project plan for Vivli § Seek immediate implementation to support gaps (e.g. for academic ICMJE compliance) if needed § Capital: 0 § Operational: 2-2.5 FTEs ~ $400 – 500K – Leadership: 1 FTE – Project manager: 1 FTE – SME: 1 FTE (mix of partial or full-invested time)
Potential Revenue Streams
§ Grants and donations
Advocate & Lobby
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0 – 6 Months 6 – 18 Months 18 – 36+ Months
Timeline Details: Medium term – 6 to 18 months
Key Considerations / Requirements Investment Required (annualized)
§ Facilitate transition / partnering of existing platform to Vivli § Launch cross-platform services by facilitating connectivity and uniformity of approach (IRP, DSA etc) § Achieve user base growth / positive indications for user base growth for cross-platform/academic data) § Create and release RFP to conduct technology build § Enact detailed project plan (earlier in phase) § Begin to defining services and capabilities for which Vivli may be able to generate revenue (e.g. data warehousing for academics) § Capital: $5M - $10M § Operational: 19 – 25 FTEs ~ $2M – $4M* – Leadership / management: 5 FTEs (3 from prior stage plus two additional) – Technology: 5-7 FTEs – Service: 3-5 FTEs – Operations: 6-8 FTEs
Potential Revenue Streams
§ Grants and donations § Data repository services for academics and
§ Data Anonymization / De-identification § Data submission support services § Annual Subscription § Proposal Review & Refinement § Pay Per Use / Request § Data retrieval § Value add services § Rare disease populations § Advertising
Advocate & Lobby Partner & Assemble
* For off-the-shelf purchases, vendor FTEs could be included, reducing total number of projected FTEs81
0 – 6 Months 6 – 18 Months 18 – 36+ Months
Timeline Details: Longer term – 18 to 36+ months
Key Considerations / Requirements Investment Required (annualized)
§ Expand technological capabilities to improve efficiency and capability of platform § Achieve sustainable revenue generation § Increase industry / academic organization participation § Expand service offerings § Proceed with detailed project plan § Interface / engage with regulators this should be in lobby/ advocate and should be earlier § Capital: TBD § Operational: TBD – Leadership / management: 5+ FTEs (TBD) – Technology: 7+ FTEs (TBD) – Service: 5+ FTEs (TBD) – Operations: +8 FTEs (TBD)
Potential Revenue Streams
§ All revenue streams from prior phase § Access to Tools § Customized report generation services
Partner & Assemble Build / Develop Advocate & Lobby
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Revenue considerations & proposed approach
§ Over the next 36 months “revenue” should refocused towards grants and charitable donations – If near-term includes support for ICMJE requirements, earlier revenue options may available § The rationale is as follows: – Services will take time to launch, and should be refined and enhanced before charging users – Services and capabilities should be extensible for interoperability with Vivli / other platforms – The barrier to entry for investigators should be kept low – Time will allow positive interactions with partners, reviews and press coverage of effort to build – Prices should be in-line with what industry and stakeholders are willing to pay – “Non-profit” title will facilitate collaboration and should de-incentivize competition § Once a substantial user base / repository size is established revenue generation can be expanded
Executive Summary
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Summary
§ Building a technology will require significant effort and investment and may not allow flexibility to change directions if the marketplace changes dynamically § Assemble and Partner offer significant flexibility for marketplace demands / disruptions and may be cheaper, faster options in the near-term § In the immediate-term (~6 months), the lowest risk option is Advocate and Lobby with an emphasis
§ Despite feasibility of launching revenue streams in the medium term (6-18 months), focus on securing grants, donations, and other philanthropic sources of support
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Key questions for discussion
Potential operating model options:
§ Are there other operating models that could be perceived as distinct from the ones presented? § Does the group agree on the choices and tradeoffs therein?
Near term operating model evolution:
§ Does the near term evolution of Vivli seem sensible? § Are there assembly / partnership activities we can take on in the near term? What other near term considerations should we keep in mind? § What capabilities do we want to focus on to achieve: – Partner? – Assemble? – Build? Can the build stage begin during an earlier phase than currently targeted?
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Data Sharing Workgroup Members
Co-Chairs: Wellcome Trust and MRCT Center Team Members: § Mark Barnes (MRCT) § Barbara Bierer (MRCT) § Patrick Cullinan (Takeda) § Rob Frost (GSK) § Rebecca Li (MRCT) § Peter Lyons (Deloitte Consulting) § Nicola Perrin (Wellcome Trust) § Rohin Rajan (Deloitte Consulting)
Executive Summary
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Potential evolution of Vivli’s operating model
Vivli Imperatives & Goals
§ Engage in advocacy § Align with other industry efforts § Engage with other clinical trial data sharing platforms § Screen other platforms for assembly / partnership potential § Define platform and specifications for Vivli’s efforts to expand / host clinical trial data sharing § Begin scoping potential IT “build needs” and identifying services Vivli will provide § Identify preliminary targeted revenue streams for Vivli § Socialize data sharing ecosystem with non-participating pharma / biotechs / academics § Begin developing functionality to enable Vivl’s vision and mission § Create partnerships with other platforms / data sharing organizations § Launch data sharing and value-add services § Define additional desired add-on functionality requiring further build § Engage with biotechs / academics and garner buy-in / participation § Begin facilitating exchange of data with and between non-participating biotechs / academics § Facilitate alignment with other data sharing efforts § Build additional add-on functionality (as desired) and improve and expand service offerings § Refine and operationalize the platform § Increase user base and frequency of use of platform § Streamline process and reduce burden for all through technology (donators and requestors) § Launch efforts to monetize and/or generate revenue to sustain Vivli § Test viability of existing revenue streams and determine new
Critical Success Factors
§ Define mission, scope, and timeline to establish Vivli § Widespread awareness and buy in to Vivli's mission amongst the broader industry/stakeholders (academics, regulators/editors etc) § Service offerings and revenue targets identified § Agreements / partnerships achieved with other data sharing organizations § Clearly defined scope / roles and responsibilities between Vivli and complementary organizations § If possible Vivli will endeavor to not be in “addition to” existing platforms but will assume their role/services to reduce burden § Substantial and growing user base § Technological capabilities established to facilitate data sharing § Sufficient revenue flow to sustain
Partner Assemble Build / Develop 0 – 6 Months 6 – 18 Months 18 – 36+ Months Advocate & Lobby
Presenter: Frances NuJall, European Medicines Agency
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European Medicines Agency Policy on publication of Clinical Data for medicinal products for human use (policy 0070)
MRCT CENTRE – Wellcome Trust meeting The Future of Clinical Trial Data Sharing
Frances Nuttall, Senior Policy Adviser, EMA, 21 March 2016
Policy purpose + objective
Clinical Data Publication policy 91
To date:
New policy:
What is it:
confidence
knowledge in future research, increases efficiency of medicine development, learning from experience
scientific knowledge, contribution to public health, confirmation of regulatory decisions/need to review regulatory decisions taken.
Benefits:
Clinical data publication policy & Clinical Trial Regulation
Clinical data publication policy: all the clinical reports (trials located in EU or non EU) in the regulatory submission to EMA
Clinical Data Publication Policy 92
Clinical Trial Regulation: EU clinical trials
Clinical data publication policy
Clinical Trial Regulation
Clinical Data Publication policy 93
Policy effective: 2015
1 January 2015: Marketing authorisation applications
applications pre
Innovation
1 July 2015: extension of indication and line extensions
To add later: post authorisation regulatory categories Not in scope: Legacy data, pre 2015
Clinical Data Publication Policy scope
Two phase implementation
summary, clinical study reports, protocol & amendments, sample case report form, documentation of statistical methods
Clinical Data Publication policy 94
Policy implementation
Introduction, scope, definitions
External guidance on the procedural aspects related to the submission of clinical reports for the purpose of publication in accordance with EMA policy 0070 Guidance on the identification and redaction of commercially confidential information (CCI) in clinical reports submitted to the EMA Guidance to pharmaceutical industry on the anonymisation of clinical reports for the purpose of publication in accordance with EMA policy 0070
Published on EMA website: 3 March 2016
Clinical Data Publication Policy 95
Clinical Data Publication Guidance
Clinical reports public presentation
Commercially confidential information (CCI) EMA position: majority of clinical report content is not CCI Redaction principles set out in the policy The company justifies each redaction, EMA reviews redactions & decides if accepted or not
Clinical Data Publication policy 96
Anonymisation Data utility: important for researchers, EMA encourages utmost data utility, balance to protect personal data, EMA guidance recommends methodology to avoid (re)identification of clinical trial participants, various techniques, evolving area. Anonymisation report: requirement, reviewed by EMA + published, shows the company’s approach for the specific case.
Access to clinical data published
Watermark:
The EMA applies a watermark to the clinical reports before their publication to emphasise the prohibition of their use for commercial purposes The watermark text is: “www.ema.europa.eu This document cannot be used to support any marketing authorisation application and any extensions or variations thereof”
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General information purpose:
§ View on screen only (no save, download, print, copy). § Digital rights management applied. § Text searchable. § Minimum user registration requirement. § Specific Terms of Use
Academic/non-commercial research purpose:
Watermark Samples
Clinical Data Publication Policy 98
These examples follow how the watermark will be presented on the published information
Clinical Data Publication Policy 99
Other companies are being informed to wait, for now, until EMA contacts them . EMA will work forward chronologically from this point. It will take time to recover the ‘waiting list’ . EMA will contact the first company with a product coming under the policy granted a CHMP opinion (September 2015).
Operational start up beginning
Learning curve for all parties
Preparation to Go-Live
Clinical Data Publication policy 100
Implementation status + issues
Go live current forecast:
regulatory decision
Public website:
understanding
conclusions
to include a list of the non-compliant companies
the various stages of the process, EMA will take remedial action including, where appropriate, publication of a non-compliance notice
Consequences
Conclusions
Clinical Data Publication policy 101
medicinal products
confidence
knowledge in future research, increases efficiency of medicine development, learning from experience
exposure
scientific knowledge, contribution to public health, confirmation of regulatory decisions/need to review regulatory decisions taken.
Policy Benefits:
Thank you for your attention
European Medicines Agency
30 Churchill Place • Canary Wharf • London E14 5EU • United Kingdom
Telephone +44 (0)20 3660 6000 Facsimile +44 (0)20 3660 5555 Send a question via our website www.ema.europa.eu/contact
Further information
Follow us on @EMA_News
Presenter: Ida Sim, University of California, San Francisco Moderator: Brian Bot, Sage Bionetworks
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The MRCT Center’s Data Sharing Workgroup Members
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IT Work Stream Co-Chairs: Ida Sim (UCSF) Barbara Bierer (MRCT Center) George Alter (U of Michigan) Munther Baara (Pfizer) Kris Bolt (MRCT Center) Brian Bot (Sage Bionetworks) Anne Claiborne (IOM) Khaled El Emam (U of OSawa) Nick Ide (NIH) Ghassan Karam (WHO) Michael Khan (U of Colorado) Sean Khozin (FDA) Rebecca Kush (CDISC) Rebecca Li (MRCT Center) Gene Lichtman (HCRI) Michelle Mancher (IOM) Chris Mavergames (Cochrane) Eric Perakslis (Takeda) Frank Rockhold (Duke)
Data Sharing PlaUorm IT Workgroup: Main Objec2ves
– develop the Data Sharing blueprint – make recommenda2ons that would enable broader data sharing of clinical trials data
technical requirements, administra2ve recommend- a2ons and suggested developmental stages of the Vivli plaUorm.
assump2ons about building the solu2ons versus partnering with exis2ng technologies
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Approach to the Work
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Use Case Documents –Define scope, u2lity and feature set of IT plaUorm including:
with the plaUorm to find, request, and analyze data
unpublished data from studies
deposit data in the plaUorm
standardiza2on issues
MRCT Center IT Workgroup
PlaForm Use Cases Data Sharing PlaUorm
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MRCT Center IT Workgroup
PlaUorm Use Cases Data Sharing PlaForm
Approach to the Work
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greater sharing and new paths to data analysis
Most Important Topics that Came Up
PlaForm Topics IPD Intake and CuraHon Must be able to intake and curate data with flexibility to scale to new types of data Catalog Metadata and Dataset IdenHfiers Must have accurate structured metadata and unique iden2fiers for each dataset, to enable precise granular searching Review Process for Requests Must be able to accommodate different review requirements and processes AnonymizaHon and DUAs Cri2cal to maintain par2cipant privacy Analysis Tools and Workspace Must have a secure analysis space, enabling as much cross-dataset aggregra2on as possible, with the flexibility to develop accommoda2on of many types of tools
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Use Case: Data Browse, Request, Access
PrecondiHons PlaForm AcHons Post CondiHons
interest
searching and browsing Search interface supports granular queries about study design features Requester iden2fies studies for which they are interested in the IPD
the PlaUorm
for data request Work flow to support review of request Request approved or denied
request Confirm that IPD is available and curated to comply with request; authen2cate access; provide secure analy2c environment Requestor has sufficient access to analysis tools and IPD and associated study materials to complete desired analysis
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Data Requester searches PlaUorm, iden2fies studies of interest, submits a request for access to available Full Data Package and/or Post Publica2on Data Packages
New Func2onality to Enable New Paths to Data Analysis
precise queries on study design features, e.g.,
– studies tes2ng meUormin in women with PCOS and Stage 1-3 CKD – studies tes2ng carvedilol for heart failure 6 and 12 months ajer acute myocardial infarc2on
– e.g. beyond medicine tested, medical condi2on or study phase
be more structured and computable, and accurately completed
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Vivli can bring a value-add by building an enhanced catalog that provides structured computable informa,on on study features not searchable elsewhere When data are more discoverable and more usable, they will enable more analysis
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Discovering Datasets
Catalog Metadata Elements
studies where IPD is or will be made available
captures the catalog metadata elements in a computable way
difficult task
descrip2ons of prior treatments, details of included or excluded co- morbidi2es, and even temporal restric2ons
1. Sponsor Internal Unique ID 2. Study Title 3. Acronym 4. Secondary IDs (e.g. NCT number) 5. Study Design Type 6. Study Start Type 7. Study Comple2on Data 8. Sponsor 9. Responsible Data Contributor 10. Sample Size 11. Loca2on of Study 12. ParHcipant Features 13. IntervenHon Features 14. Outcome Features
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See Appendix 2 of Blueprint
Use Case: Submission of Catalog Metadata
PrecondiHons PlaForm AcHons Post CondiHons
ClinicalTrials.gov or ICTRP)
authority to complete submission process Assign PlaUorm Iden2fier Human (Phase 1) or machine-assisted (Phase 2) cura2on of study documents New study is fully described and discoverable in plaUorm PlaUorm can aJest to some level of accuracy in data based on cura2on process
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PI of study or Delegated data submiJer(s) with established account requests to submit data and sign contributor agreement
Metadata Cura2on Pipeline
Phase 1: Human CuraHon
ClinicalTrials.gov, ICTRP, etc.
assump2ons
validate
Phase 2: Semi-automated CuraHon
processing, text mining
extracted from protocols
allow for analysis on just the metadata
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Use Case: Submission of IPD
PrecondiHons PlaForm AcHons Post CondiHons
study is already in the PlaUorm
decided which sharing scenario (A or B) to use for this IPD dataset Mint Digital Object Iden2fier Update all study DOI links Enter study into IPD cura2on queue Study priori2zed in IPD cura2on queue Study is next up for cura2on in IPD cura2on queue If Scenario A:
format If Scenario B:
format Anonymized, curated IPD is fully indexed to the other contents of the PlaUorm, and are accessible for PlaUorm func2onality
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PI of study or Delegated data submiJer(s) With established account requests to submit data and sign contributor agreement
Overview of Vivli plaUorm data sharing scenarios
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Vivli PlaForm
Catalog Metadata Non-IPD
e.g., protocol, SAP,
Individual PaHent Data (IPD) Analy2c Environment and Tools SAS R etc.
Query, Request, and Analy2cs User Interface IPD IPD Non-IPD R
Scenario A Scenario B
Non-IPD SAS
Possibility to aggregate datasets across SAS environments
Data Requester
PlaUorm Schema2c: Scenario A
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stored by the PlaUorm for analysis and combina2on with all other data that is shared on the plaUorm
data, host does not have further
sharing.
Data Requester
Vivli PlaForm
Catalog Metadata Non-IPD
e.g., protocol, SAP,
Individual PaHent Data (IPD) Analy2c Environment and Tools SAS R etc.
Query, Request, and Analy2cs User Interface IPD
Scenario A
Non-IPD
PlaUorm Schema2c: Scenario B
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for analysis and combina2on with all other data shared on plaUorm
combined/analyzed with data outside of their analysis environment which provides tools and space for requesters
Vivli PlaForm
Catalog Metadata Non-IPD
e.g., protocol, SAP,
Individual PaHent Data (IPD) Analy2c Environment and Tools SAS R etc.
Query, Request, and Analy2cs User Interface IPD Non-IPD R
Scenario B
SAS
Possibility to aggregate datasets across SAS environments
Data Requester
Use Case: Submission of IPD
PrecondiHons PlaForm AcHons Post CondiHons
study is already in the PlaUorm
decided which sharing scenario (A or B) to use for this IPD dataset Mint Digital Object Iden2fier Update all study DOI links Enter study into IPD cura2on queue Study priori2zed in IPD cura2on queue Study is next up for cura2on in IPD cura2on queue If Scenario A:
format If Scenario B:
format Anonymized, curated IPD is fully indexed to the other contents of the PlaUorm, and are accessible for PlaUorm func2onality
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PI of study or Delegated data submiJer(s) With established account requests to submit data and sign contributor agreement
IPD Cura2on Queue: Priori2za2on and Cura2on Flow
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PrioriHzaHon order for datasets submiJed under Scenario A
CuraHon flow to achieve curated, anonymized IPD
3
Individual Participant Data (IPD)
in SDTM not in a standard model to be put into SDTM by Vivli by sponsor leave unstandardized
curated, anonymized IPD
anonymized in SDTM anonymized in SDTM basic anonymization
1 2
2a 2b
Phased Development Approach
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Authen2ca2on / Iden2ty Management
Review process for requests Review brokering: referral to qualified external reviews Single plaUorm managed review process Harmonized review process Repository metadata & data set iden2fiers Unique study iden2fiers Secure storage Data set DOI Smart dataset cita2on & academic credit, archiving Dataset provenance External APIs
(e.g., to/from services)
Data intake & cura2on Core rich metadata IPD data model standard Human cura2on Harmonized common elements, non-registered studies, genomics, non- interven2onal studies Machine assist core metadata, imaging data Anonymiza2on and DUAs Standard DUA, contributor agreement, anonymiza2on verifica2on PlaUorm performed anonymiza2on service. Pa2ent level 1 way hash
Referral to approved 3rd party anonymiza2on service(s)
Analysis tools & workspace R, SAS & others Visualiza2on, advanced analy2cs, collabora2ve work, scien2fic workflows External APIs
(e.g., to open source tools)
BROKER
search, browse, requests, access, analysis Phase 1 Min: Dec, 2017 Phase 1+ Phase 2 possibili2es
Complex Assembly
considera2ons
– Services to be developed
– Iden2fy possible partners
forthcoming policy discussions
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Q&A
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Facilitated Discussions
and opportunity to provide feedback on Governance, Business Models and Data Sharing PlaUorm
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Presenter: Mark Barnes, MRCT Center
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Presenter: Jeremy Farrar, Wellcome Trust
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Royal College of General Prac,,oners 30 Euston Square, London
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