What is it? Why is it important?

Chapter 3 of the HRO regulates research related to the further use of:

  • Sampled Biological Material (BM) collected as per routine procedures
  • Collected health-related personal data (HRpD) collected as per routine procedures

According to the law, Informed Consent (IC) procedures must be adapted based on whether project data:

  • Contains genetic information from participants
  • Is un-coded: participant identifiers (e.g. name, address, DOB) are documented together with participant / project HRpD
  • Is coded: participants are allotted individualised project IDs. IDs together with participant identifiers are kept separate from participant/project HRpD data (e.g. a Participant Identification Log)
  • Is anonymised: means required for participant identification has been deleted (e.g. participant identifiers, project ID, Participant Identification Log)

More

Different IC regulations apply based on:

  • Whether the project includes the further use of genetic or non-genetic data
  • How BM / HRpD database is stored in the database (e.g. un-coded, coded, anonymised)

IC regulations for further use of genetic BM / HRpD:

  • Un-coded: project information to participants must be provided in writing and orally and consent is given in writing
  • Coded: project information to participants must be provided in writing or orally and consent is given in writing
  • Anonymisation: project information to participants must be provided in writing or orally and the participant does not dissent to anonymization

IC regulations for further use of non-genetic HRpD:

  • Un-coded: project information to participants must be given in writing or orally and consent is given in writing
  • Coded: project information to participants must be given in writing or orally and participant gives no dissent to data collection

What do I need to do?

As a researcher apply IC procedures based on:

  • Planned further use of HRpD (genetic / non-genetic) and BM (genetic)
  • How participant information is stored in the project database (e.g. un-coded, coded, anonymised)

Adaptations include how:

  • Participants are informed about the project, which is either:
    • In writing and orally
    • In writing or orally
  • IC is collected from participants, which is either:
    • In writing
    • Participant does not dissent to its BM / HRpD being used for research

As a researcher responsible for a particular research site:

  • Define local IC procedures
  • Define how the Participant ID Log can be protected from unauthorised access and accidental disclosure (e.g. access is only permissible by authorized staff)

More

Participants must provide consent and the EC must approve the project prior to using data for research purposes.

In exceptional cases where participant IC is missing, the EC will evaluate and decide whether data from participants with missing consent can be used in the project. Aspects to clarify for EC include:

  • Is it impossible or disproportionately difficult to obtain consent or to provide information on the right to dissent, or would this impose an undue burden on the person concerned?
  • Are there any documented refusals?
  • Do research interests outweigh the interests of the person concerned in deciding on the further use of his or her biological material and data?

Where can I get help?

Your local CTU↧ can support you with experienced staff regarding this topic

External Links

Swissethics – see in particular

  • Templates and checklists
    • Study protocols / Further use with consent

Swiss Law

FEDLEX – law are available online under number

  • 810.30 HRA
  • 810.301 HRO

HRA – see in particular article

  • Art. 34 Absence of informed consent

HRO – see in particular chapter / section

  • Chapter 3, section 2. Informed Consent and Information
Abbreviations
  • BM – Biological Material
  • CTU – Clinical Trials Unit
  • DOB – Date of Birth
  • EC – Ethics Committee
  • FEDLEX – Publication Platform for Federal Laws
  • HRA – Human Research Act
  • HRO – Human Research Ordinance
  • HRpD – Health-Related Personal Data
  • IC – Informed Consent
  • ID – Identification
Basic ↦ Ethics and Laws ↦ Human Research Ordinance ↦ Further use and Informed Consent
Study
Basic

Provides some background knowledge and basic definitions

Basic Protocol
Basic Management
  1. Study Management
    1. Definition
Basic Ethics and Laws
  1. Principles of Ethics Research
    1. Declaration of Helsinki
    2. Declaration of Taipei
  2. Authorities
    1. Ethics Committee
    2. Swissmedic
    3. Federal Office of Public Health
    4. International
  3. Swiss Law
    1. Human Research Act
    2. Transplantation Act
    3. Stem Cell Research Act
    4. Data Protection Act
  4. Clinical Trials Ordinance
    1. Aim
    2. Medicinal Products
    3. In Vitro Diagnostic Medical Device
    4. Standardized Transplant Products
    5. Gene Therapy, GMO, Pathogenic
    6. Transplantation
    7. Other Clinical Studies
    8. Ionising Radiation
  5. Human Research Ordinance
    1. Aim
    2. Projects with Data and Biological Material
    3. Further use of Data and Biological Material
    4. Further use and Informed Consent
    5. Deceased Persons Embryos and Foetuses
  6. Medical Device Ordinance
    1. Aim
    2. In Clinical Studies
    3. Notified Bodies
  7. Organisation Ordinance
    1. Aim
  8. Portals
    1. Human Research Portal
    2. Ethics Portal BASEC
    3. Swissmedic Portal
  9. Guidelines
    1. Good Clinical Practice
    2. ISO 14155
    3. ISO 20916
Basic Documents
  1. Document Management
    1. Purpose
    2. In Studies
    3. Document Identification
    4. Document Filing
  2. Standard Operating Procedures
    1. Purpose
  3. Working Instructions
    1. Purpose
  4. Logs
    1. Purpose
  5. Essential Documents
    1. Requirement
  6. Certified Copies
    1. Procedures
  7. Staff Documents
    1. Qualifications
    2. Training
Basic Safety
  1. Safety Laws
    1. Aim
  2. Safety Terminology
    1. Overview
  3. Safety Data
    1. Product Development
    2. Pre-Clinial Studies
    3. In Clinical Studies
  4. Safety Information
    1. Investigator Brochure
  5. Safety Vigilance
    1. Pharmacovigilance
    2. Materiovigilance
Basic Data Handling
  1. Data Management in Studies
    1. Aim
  2. Study Database
    1. Clinical Data Management System
    2. Study Data
    3. Raw Data
    4. Metadata
  3. Regulatory Requirements
    1. Swiss Law
    2. General Data Protection Regulation
Basic Statistics
Basic Quality and Risk
  1. Risk Management Definitions
    1. Risk-Based Approach
    2. Risk Identification
    3. Risk Evaluation and Prioritisation
    4. Risk Evaluation Matrix
    5. Risk Control Measures
  2. Quality Management System (QMS)
    1. Risk Based
  3. Risk-Based QMS Responsibilities
    1. Sponsor-Investigator
    2. Site-Investigator
    3. Study Staff
Basic Monitoring
Basic Drug or Device
Basic Biobanking
Concept

Starts with a study idea

Ends after having assessed and evaluated study feasibility

Concept Protocol
Concept Management
  1. Study Idea
    1. Implementation
    2. Design
  2. Resources
    1. Study Staff
    2. Infrastructure
    3. Storage
    4. Partners
    5. Budget
Concept Ethics and Laws
  1. Study Categorisation
    1. Procedures
    2. Risk Categories
  2. Regulatory Advice
    1. Scientific Advice
    2. Pre-Submission
  3. Regulatory Advice Meeting
    1. Ethics Clarification
  4. Research Aim
    1. Advancing Science
    2. Marketing Products
  5. Research Integrity
    1. Principles
    2. Conflict of Interest
    3. Participant Protection
  6. Study Planning
    1. Ethics Requirements
    2. Laws and Guidelines
    3. Institution Requirements
  7. Study Feasibility
    1. Ethics and Laws
Concept Documents
  1. Required Documents
    1. Protocol and Synopsis
    2. Feasibility
    3. Investigator's Brochure
Concept Safety
  1. Safety in Studies
    1. Risk-Benefit Ratio
    2. Participant Risk-Benefit
Concept Data Handling
  1. Stakeholders
    1. Sponsor-Investigator
    2. Data Manager
    3. Statistician
    4. Site-Investigator
    5. Monitor
  2. Clinical Data Mgmt. System
    1. Selection
  3. Server
    1. Data Storage
    2. Back-Up and Recovery
Concept Statistics
Concept Quality and Risk
  1. Study Feasibility
    1. Aim
    2. Feasibility Questionnaire
    3. Risk Assessment Form
    4. Study Team
Concept Monitoring
  1. Monitoring
    1. Aim
    2. Study Requirement
    3. Site Feasibility
Concept Drug or Device
Concept Biobanking
Development

Starts with confidence that the study is feasible

Ends after having received ethics and regulatory approval

Development Protocol
Development Management
  1. Responsibilities
    1. Sponsor-Investigator
    2. Site-Investigator
    3. Staff Qualification and Training
    4. Good Clinical Practice Training
  2. Quality Mgmt. System
    1. Implementation
    2. Interim Analysis
  3. Study Management
    1. Oversight
    2. Tracking
    3. Infratructure and Maintenance
    4. Multi-centre Studies
    5. Insurance
    6. Outsourced Services
    7. Contract
    8. Budget
  4. Study Documents
    1. Protocol
    2. Participant Information Sheet
    3. Informed Consent Form
    4. Exemption from written Consent
    5. Informed Consent Process
    6. General Consent
    7. Essential Documents
    8. Source Data
  5. Study Approval
    1. Ethics Committee
    2. Swissmedic
    3. Fed. Off. Public Health
  6. Biobanking
    1. Management
    2. Emergency Plan
Development Ethics and Laws
  1. Ethics Application
    1. Submission
    2. Application Dossier
    3. Approva
  2. Swissmedic Application
    1. Application Dossier
    2. Early Clarification Meeting
    3. Late Clarification Meeting
    4. Approval Medicinal Products
    5. Approval Medical Device
  3. Federal Office of Public Health
    1. Submission
    2. Approval
  4. Liability
    1. Insurance
    2. Good Clinical Practice
Development Documents
  1. Required Documents
    1. Study Protocol
    2. Participant Information
    3. Insurance and Contract
    4. Study Documents
    5. Document Submission
Development Safety
  1. Safety Documentation
    1. The Protocol
    2. Study Documents
    3. Data Protection
Development Data Handling
  1. Study Database Set-Up
    1. Variables
    2. Variable Specification
    3. Case Report Form
    4. Automated Data Processing
    5. Data Confidentiality
    6. Data Coding and Anonymisation
  2. Data Quality
    1. Requirement
    2. Quality Management
    3. Data Mgmt. Plan
  3. Database Lock
    1. Procedures
Development Statistics
Development Quality and Risk
  1. Study Risk Management
    1. Risk Identification
    2. Risk Evaluation and Prioritisation
    3. Risk Control Measures
    4. Process Verification and Training
  2. Quality Assurance
    1. Aim
    2. Quality Documents
    3. Audit
  3. Quality Control
    1. Aim
    2. Monitoring
    3. Non-Compliance
  4. Risk Communication
    1. Strategy
Development Monitoring
  1. Montoring Strategy
    1. Aim
    2. Risk-Based Monitoring
    3. On-Site Monitoring
    4. Central Monitoring
    5. Monitoring Plan
Development Drug or Device
Development Biobanking
Set-Up

Starts with ethics and regulatory approval

Ends after successful study initiation

Set-Up Protocol
Set-Up Management
  1. Registration
    1. Research Transparency
  2. Study Training
    1. Staff
  3. Document Management
    1. Requirements
  4. Investigational Product
    1. In Studies
  5. Laboratory
    1. Aim
  6. Study Ready for Conduct
    1. Requirements
  7. Study Monitoring
    1. Site Initiation Visit
Set-Up Ethics and Laws
  1. Study Set-Up
    1. Requirements
Set-Up Documents
  1. Required Documents
    1. Study Initiation
    2. Master and Site File
Set-Up Safety
  1. Safety Management
    1. Safety Management Plan
    2. Emergency Unblinding
  2. Data Safety Monitoring Board
    1. Aim
Set-Up Data Handling
  1. Database
    1. Development
    2. Access Rights
    3. Training
Set-Up Statistics
Set-Up Quality and Risk
Set-Up Monitoring
  1. Site Initation Visit
    1. Aim
    2. Prerequisite
    3. Preparation
    4. Conduct
    5. Report
Set-Up Drug or Device
Set-Up Biobanking
Conduct

Starts with participant recruitment

Ends after the last participant has completed the last study visit

Conduct Protocol
Conduct Management
  1. Participant Recruitment
    1. Pre-Screening
    2. Screening and Consent
    3. Documentation of Recruitment
  2. Amendment
    1. Protocol
    2. Patient Information Sheet
  3. Safety
    1. Reporting
    2. Annual Safety Reporting
    3. Interim Analysis
  4. Responsibility and Oversight
    1. Site-Investigator
    2. Routine Monitoring
    3. Risk Review
    4. Drug Accountability
    5. Compliance
    6. Newsletter
    7. Essential Documents
    8. Budget
Conduct Ethics and Laws
  1. Study Conduct
    1. Ongoing Tasks
    2. Data Protection
  2. Participant Protection
    1. Requirements
    2. Consent of Vulnerable Participants
  3. Amendment
    1. Type
    2. Submission
    3. Approval
  4. Safety
    1. Requirements
  5. Inspections and Audits
    1. Inspection Conduct
    2. Audit Conduct
    3. Audit Certificate
  6. Premature Study Termination
    1. Rationale
    2. ReportingTimelines
Conduct Documents
  1. Required Documents
    1. Study Documentation
    2. Patient File
    3. Source Data
    4. Amendment
Conduct Safety
  1. Safety Risk Review
    1. Aim
  2. Safety Assessment
    1. Medicinal Product
    2. Medical Device
    3. Other Clinical Trials
    4. Research Projects
  3. Safety Reporting
    1. Procedures
    2. Responsibilities
  4. Medicinal Product Safety Reporting
    1. Adverse Event
    2. Serious Adverse Event
    3. (Serious) Adverse Drug Reaction
    4. Suspected Unexpected Serious Adverse Reaction
    5. Advanced Therapies
  5. Medical Device Safety Reporting
    1. Adverse Event / Adverse Device Effect
    2. Serious Adverse Event and Device Effect
    3. Device Deficiency
  6. Research Project Safety Reporting
    1. Serious Events
  7. Safety and Protective Measures
    1. Procedures
  8. Annual Safety Report
    1. Procedures
Conduct Data Handling
  1. Data Entry
    1. Requirement
    2. Collection
  2. Data Quality
    1. Responsibility
    2. Training
  3. Data Handling
    1. Data Import
    2. Interim Lock
    3. Intermediate Data Eport
    4. Amendment
Conduct Statistics
Conduct Quality and Risk
  1. Risk Review
    1. Re-Evaluation
    2. Risk Documentation
  2. Deviation Documentation
    1. Note to File
  3. Regulatory Inspections
    1. Conduct
    2. Findings
    3. Corrective and Preventive Actions
Conduct Monitoring
  1. Routine Monitoring Visit
    1. Preparation
    2. Conduct
    3. Findings
    4. Report
    5. Follow-Up Letter
Conduct Drug or Device
Conduct Biobanking
Completion

Starts with last study visit completed

Ends after study publication and archiving

Completion Protocol
Completion Management
  1. Study Closure
    1. Close-Out Visit
    2. Database Lock
    3. Notification of Closure
    4. Lessons Learned
  2. Clinical Study Report
    1. Regulatory Requirements
  3. Publishing
    1. Study Registries
    2. Scientific Publications
  4. Archiving
    1. Storage
Completion Ethics and Laws
  1. End of Study Notification
    1. ReportingTimelines
    2. Liability Coverage
    3. Registry Update
  2. Clinical Study Report
    1. Procedures
  3. Publications
    1. Responsibilities
  4. Inspections and Audits
    1. Procedures
  5. Archiving
    1. Requirements
    2. Duration
Completion Documents
  1. Required Documents
    1. Study Closure
    2. Doument Archiving
    3. Document Destruction
Completion Safety
  1. Clinical Study Report
    1. Procedures
Completion Data Handling
  1. Final Database Lock
    1. Procedures
  2. Data Export
    1. Data Formatting and Tranfer
    2. Data Transfer Agreement
  3. Clinical Study Report
    1. Requirement
  4. Archiving
    1. Requirement
Completion Statistics
Completion Quality and Risk
  1. Clinical Study Report
    1. Risk Reporting
    2. Lessons Learned
  2. Archiving
    1. Study Records
Completion Monitoring
  1. Close-Out Visit
    1. Preparation
    2. Conduct
    3. Report
    4. Follow-Up Letter
    5. Archiving
Completion Drug or Device
Completion Biobanking
Current Path (click to copy): Basic ↦ Ethics and Laws ↦ Human Research Ordinance ↦ Further use and Informed Consent

Please note: the Easy-GCS tool is currently under construction.