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NIH Collaboratory
Living Textbook of
Pragmatic Clinical Trials

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Rethinking Clinical Trials

A Living Textbook of Pragmatic Clinical Trials

  • Design
    • What is a Pragmatic Clinical Trial?
    • Decentralized Pragmatic Clinical Trials
    • Developing a Compelling Grant Application
    • Experimental Designs and Randomization Schemes
    • Endpoints and Outcomes
    • Analysis Plan
    • Using Electronic Health Record Data
    • Building Partnerships and Teams to Ensure a Successful Trial
    • Intervention Delivery and Complexity
    • Patient Engagement
  • Data, Tools & Conduct
    • Assessing Feasibility
    • Acquiring Real-World Data
    • Assessing Fitness-for-Use of Real-World Data
    • Study Startup
    • Participant Recruitment
    • Monitoring Intervention Fidelity and Adaptations
    • Patient-Reported Outcomes
    • Clinical Decision Support
    • Mobile Health
    • Electronic Health Records–Based Phenotyping
    • Navigating the Unknown
  • Dissemination & Implementation
    • Data Sharing and Embedded Research
    • Dissemination Approaches for Different Audiences
    • Implementation
    • End-of-Trial Decision-Making
  • Ethics & Regulatory
    • Privacy Considerations
    • Identifying Those Engaged in Research
    • Collateral Findings
    • Consent, Disclosure, and Non-Disclosure
    • Data and Safety Monitoring
    • Ethical Considerations of Data Sharing in Pragmatic Clinical Trials
    • Ethics for AI and ML
    • IRB Responsibilities and Procedures

Introduction

CHAPTER SECTIONS

Privacy Considerations


Section 1

Introduction

Expand Contributors

Stephanie Morain, PhD
Judith Carrithers, JD
Joseph Ali, JD
Vasiliki Nataly Rahimzadeh, PhD

Contributing Editor

Karen Staman, MS
Damon M. Seils, MA

Pragmatic clinical trials embedded in healthcare systems integrate research into routine clinical care. Therefore, data are typically collected from the electronic health record (EHR), from claims data sources, and via patient-reported outcomes. Because these data are often collected for the primary purpose of patient care and billing, and may include sensitive information, there can be privacy considerations for studies that use these data.

In this chapter, we examine privacy considerations in embedded pragmatic clinical trials by reviewing the relevant regulatory frameworks and by discussing studies that use real-word data for research. We explore privacy considerations from patient, clinician, and healthcare system perspectives.

Next Section

SECTIONS

CHAPTER SECTIONS

sections

  1. Introduction
  2. Current Federal Regulatory Framework: Common Rule, FDA, and HIPAA
  3. Additional Protections: Certificates of Confidentiality
  4. Individual Privacy
  5. Clinician and Institutional Privacy Considerations

Resources

Post-Trial Responsibilities in Pragmatic Clinical Trials: Fulfilling the Promise of Research to Drive Real-World Change
Article from the Ethics and Regulatory Core

Ethical Considerations for Sharing Aggregate Results From Pragmatic Clinical Trials
Article from the Ethics and Regulatory Core


Version History

July 3, 2025: Added the Resources sidebar and made nonsubstantive changes to the text as part of the regular content review (changes made by D. Seils).

Published September 27, 2022

current section :

Introduction

  1. Introduction
  2. Current Federal Regulatory Framework: Common Rule, FDA, and HIPAA
  3. Additional Protections: Certificates of Confidentiality
  4. Individual Privacy
  5. Clinician and Institutional Privacy Considerations

Citation:

Morain S, Carrithers J, Ali J, et al. Privacy Considerations: Introduction. In: Rethinking Clinical Trials: A Living Textbook of Pragmatic Clinical Trials. Bethesda, MD: NIH Pragmatic Trials Collaboratory. Available at: https://rethinkingclinicaltrials.org/chapters/ethics-and-regulatory/special-privacy-considerations/introduction/. Updated December 3, 2025. DOI: 10.28929/170.

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