Data Use Agreements

The Office of Research Integrity (ORI) recently took on the role of centrally managing Data Use Agreements that involve research data. From start to finish, ORI will coordinate all behind-the-scenes required reviews (e.g., with CIS, OGC, etc.) and work expeditiously to bring draft agreements to execution on behalf of the investigator. The Office of Research Integrity requires completion of the Data Use Agreement (“DUA”) Request form for all proposed incoming and outgoing DUAs to ensure that appropriate terms & conditions are negotiated.  Please email any questions about the request or this form to 

What is a Data Use Agreement (DUA)?

When don't I need a DUA?

Where do I obtain a DUA?

Who has authority to sign a DUA?

Storing and Sharing Data

How do I initiate review of a DUA?

Documents required for submission

What is a Data Use Agreement?

A Data Use Agreement (DUA), sometimes referred to as a Data Transfer Agreement (DTA) or Data Sharing Agreement (DSA) or other variations on these terms, is a formal, written agreement into which two parties enter that establishes specific ways in which the data may be used and how it must be protected. Often, this data is a necessary component of a research project. It may or may not be human subject data from a clinical trial, or a Limited Data Set as defined in HIPAA. Importantly, investigators may not enter Brown University into such agreements -- review and signature is required by a responsible party on behalf of the University (which is not the PI).

A data use agreement (DUA) provides that the recipient of the data will:

  • not use or disclose the information other than as permitted by the DUA or as otherwise required by law,

  • use appropriate safeguards to prevent uses or disclosures of the information that are inconsistent with the DUA,

  • report to the providing party uses or disclosures that are in violation of the DUA, of which it becomes aware,

  • ensure that anyone to whom the receiving party provides the information to abides by the same restrictions and conditions that apply to the original recipient with respect to such information, and

  • not re-identify the information or contact an individual and, if stated in the DUA, not combine the data with other datasets.

Data Use Agreements may be incoming, when an external party will be sharing data with Brown, or outgoing, when Brown will share data with an external party.

When don’t I need a DUA?

  • When data is publicly available in the public domain.

  • When data is exchanged that is not subject to a legal or other restriction on its use.

  • When de-identified data is exchanged for research purposes under a subcontract or other form of agreement with the recipient.

Where do I obtain a DUA?

If the Brown researcher is the recipient of research data from a non-Brown entity:

  • The Brown researcher will most likely be asked to sign the other party’s DUA. Please begin by completing a DUA request form to submit this information to the Office of Research Integrity for review. If the providing entity does not have a standard template for a proposed agreement, the researcher should consult with the ORI directly.

If the Brown researcher is the providing party of an identifiable dataset:

  • The ORI is utilizing a DUA form template for use by Brown researchers who wish to disclose research data to recipients. The Brown researcher must first complete a DUA Request Form to submit this information to ORI for review. Don't hesitate to reach out to if you have any questions or if you would like to schedule a meeting to discuss a DUA.

Who signs DUAs?

The Office of the Vice President for Research (OVPR) at Brown University is authorized to enter into research agreements, including DUAs, on behalf of the University. ORI facilitates review and approval of all data contracts and data sharing agreements. Before forwarding the agreement to ORI for University signature, it is important for the researcher to read the terms of a DUA and agree to abide by those terms

  • The Office of the Vice President and General Counsel (OGC) as well as Computing and Information Services (CIS) may be consulted in the review and approval of any data security management plans and negotiation of applicable terms. Please allow for additional time that is usually required for these reviews.​

  • Researchers are not authorized to sign agreements on behalf of the University. If a researcher signs such an agreement on behalf of the University, the researcher could be subjected to legal and financial risks and the agreement is non-binding.

  • The School of Public Health leadership has authorization to review and sign its own Data Use Agreements for Centers for Medicare and Medicaid Services data.

Other information:

Storing and Sharing Data:

What is a limited data set?

A “limited data set” is defined as health information that excludes certain direct identifiers (listed below).

The Privacy’s Rule limited data set provisions requiring the removal of direct identifiers apply both to information about the individual and to information about the individual's relatives, employers, or household members.

The following identifiers must be removed to qualify as a limited data set:

  1. Names

  2. Street address information (other than town or city, state, and zip code)

  3. Telephone numbers

  4. Fax numbers

  5. E-mail addresses

  6. Social security numbers

  7. Medical record numbers

  8. Health plan beneficiary numbers

  9. Account numbers

  10. Certificate/license numbers

  11. Vehicle identifiers and serial numbers (including license plate numbers)

  12. Device identifiers and serial numbers

  13. Web universal resource locators (URLs)

  14. Internet protocol (IP) address numbers

  15. Biometric identifiers, including fingerprints and voiceprints

  16. Full-face photographic images and any comparable images

A limited data set may include:

  1. Dates such as admission, discharge, service, DOB, DOD;

  2. city; state; zip code; and

  3. age in years, months or days or hours.

To Initiate Office of Research Integrity (ORI) review:

  1. PI completes DUA Request Form

  2. Upon electronic receipt of a new request, the Office of Research Integrity will begin initial submission review and will contact the PI and the administrative contact listed in the submission if any of the required documentation is missing or incomplete.

  3. Once the terms have been finalized, the agreement will be circulated for signature.

  4. Once the agreement has been fully executed (signed by all parties), a PDF copy will be provided to the PI and to the administrative contact listed in the submission.

Documents required for submission:

  1. Completed DUA Request Form

  2. Proposed DUA (as an editable Word document) or request to use Brown DUA template (if Brown is receiving data from another entity)

  3. IRB approval letter (for human subjects research data)

Need help?

Please contact us at


Please contact Kelsey MacKinnon, Research Agreement Manager at

Nominate a faculty member for a Brown Research Achievement Award

The Office of the Vice President for Research (OVPR) is pleased to announce an inaugural awards program during academic year 2016-2017 to recognize outstanding research achievements of Brown faculty. Five awards will be given annually that each carry a research stipend of $5,000. A committee of faculty will review nominations and select the award recipients. OVPR invites nominations from deans, department chairs, and center directors, and also invites self-nominations and nominations by colleagues. 

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