In structuring biobank interaction with secondary researchers, biobanks will need to establish DAC and ICOB (or other IF/IRR committee) policies to assure that secondary researchers take steps to facilitate sound handling of IFs and IRRs.20 Secondary researchers will need to address in their application for access to data and/or samples the potential of their research to generate IFs and IRRs that may be returnable. To facilitate this judgment, the secondary researchers will need to receive from the biobank a document specifying what IFs and IRRs are deemed returnable. The closer this document is to an actual roster of returnable findings, the easier it will be for secondary researchers to respond. Secondary researchers are already commonly asked to agree that they will refrain from re-identifying contributors. MTAs and DAAs or DUAs between the biobank and secondary researchers should reflect all of these understandings.
