=Paper=
{{Paper
|id=Vol-1788/STIDS2016_T06
|storemode=property
|title=Sharing Data under Genetic Privacy Laws
|pdfUrl=https://ceur-ws.org/Vol-1788/STIDS_2016_T06_Reep_etal.pdf
|volume=Vol-1788
|authors=Michael Reep,Bo Yu,Duminda Wijesekera,Paulo C. G. Costa
|dblpUrl=https://dblp.org/rec/conf/stids/ReepYWC16
}}
==Sharing Data under Genetic Privacy Laws==
Sharing Data under Genetic Privacy Laws Michael Reep*, Bo Yu*, Duminda Wijesekera*, Paulo Costa † * Department of Computer Science, George Mason University, Fairfax, VA, USA mreep@gmu.edu, byu3@gmu.edu, dwijesek@gmu.edu † Department of Systems Engineering and Operations Research, George Mason University, Fairfax, VA, USA pcosta@gmu.edu Abstract— Clinical medical practice and biomedical research * Ethics - Privacy of genetic data differs from utilize genetic information for specific purposes. Irrespective of the purpose of obtaining genetic material, methodologies for traditional medical information privacy. For protecting the privacy of patients/donors in both clinical and example, protecting patients’ private information research settings have not kept pace with rapid genetic advances. (e.g., Protected Health Information - PHI) is an When the usage of genetic information is not predicated on the important medical ethics and legal obligation. Data latest laws and policies, the result places all-important patient/donor privacy at risk. Some methodologies err on the side for genotype-phenotype matching can be used to of overly stringent policies that may inhibit research and open- stigmatize or discriminate against genetic relatives of ended diagnostic activity, whereas an opposite approach advocates a donor, so the dangers of its exposure must be a high-degree of openness that can jeopardize patient privacy, carefully weighed against the benefits of its use [1, 4, identifying patient relatives and erode the doctor-patient privilege. As a solution, we present a unique approach that is based on the 5]. There is an ongoing ethical debate between the premise that acceptable clinical treatment regimens are captured two different schools of thought, one in which the in workflows used by caregivers and researchers and therefore donor gives open consent for using his/her data vs. their associated purpose can be extracted from these workflows. the other that advocates explicit purpose-based We combine these purposes with applicable consents (derived from applicable laws) to ascertain the releasability of genetic consent [6]. information. Given that federal, state and institutional laws govern the use, retention and sharing of genetic information, we * Legal Issues - Due to the unusual situation of create a three-level rule hierarchy to apply the laws to a request being able to expose relative’s genetic composition, and auto-generate consents prior to releasing. We prototype our genetic privacy has been proposed as categorical system using open source tools, while ensuring that the results can privacy that differs from traditional individual- be added to existing Electronic Medical Records (EMR) systems. centered concepts of privacy in literature [7]. Federal Keywords—genetic privacy, electronic medical records, (HIPAA and GINA) [8, 9], state laws and ontology, health care, genomic medicine, SWRL institutional polices provide the legal framework for the sharing of genetic information. Furthermore, I.INTRODUCTION genetic privacy laws vary from state-to-state and may Genetic studies match genotypic and phenotypic be inconsistent with, or more or less stringent than, data to associate genetic markers with onset of federal regulations. diseases [1]. Studies have shown that preventive care * Social Implications - Societal views are often costs significantly less than treatment upon disease reflected in law and/or organizational policies, so onset and diagnosis [2, 3]. Furthermore, rapid their implications are likely inextricably intertwined advancement of genetic research continues to with laws and policy governing genetic privacy and lengthen the list of predictable diseases. Examples what constitutes informed consent. include genetic mutations causing some breast cancers (BRC-1 and BRC-2), ovarian cancer, sickle As a solution, we provide an encompassing cell anemia, β-thalassemia, left ventricular framework consisting of workflow-enforced genetic noncompaction cardiomyopathy and Alzheimer’s privacy as well as biomedical consent management, disease. However, both research and clinical use of consistent with state and federal genetic privacy laws genetic information entail privacy challenges that such as statute, regulation and precedent. Following differ from usage of other medical data in following this Introduction, Section 2 addresses related work; ways: Section 3 reviews the prototype design and ontology, STIDS 2016 Proceedings Page 46 Section 4 describes the implementation of our genetic research participants to understand and decide how services workflow that enforces appropriate informed the medical community can use and share their consent based on applicable law to achieve genetic identifiable medical information. Analogously, privacy; and, finally, Section 5 presents conclusions. informed consent tailored for genetic research, clinical usage and counseling constitutes a strong II. RELATED WORK basis for ensuring appropriate genetic privacy. Some Many researchers have suggested adopting genetic medical practices and biomedical research traditional information protecting methodologies to are performed without obtaining appropriate protect patients’ confidentiality. Yet, this might not informed consent such as enticing participants in a be effective due to the uniqueness of being traceable study without obtaining the proper informed consent. to an individual or group of individuals [10, 11]. To address this issue, some researchers advocate After all, some genetic information of an individual different methodologies such as using highly- may not only precisely identify him/her as high risk stringent policies to maintain patient confidentiality, of certain hereditary disease(s), but also indicate that but this approach potentially risks limiting scientific his/her relatives have the same risks due to a innovation [18]. Yet, other researchers have heritable gene. proposed a new, open-consent model for medical and scientific genetic research [7] or open-access policies Prince et. al. describe three practical genetic for genetic data sharing [19]. As the underlying counseling cases that illustrate genetic predicate for us undertaking this effort, we proposed discrimination [12]. The fundamental covenant of a prototype system capable of automatically protecting patient privacy is embodied in patient- generating or obtaining appropriate informed doctor privilege. Conversely, many scholars believe consent forms for genetic data sharing under various genetic information is essentially familial in nature situations. and is referred to as the Genetic Information is Familial Thesis (GIFT) [13], since sharing such EMRs play a vital role of sharing medical information will benefit related groups of information among participating actors based on individuals. Some countries have regulations to their usage scenarios. Using EMRs for genetic enforce sharing such information among family services present a unique set of challenges [20]. members [14, 15]. However, many publications Belmont et al. highlighted the privacy, ethical and discuss and debate the familial approach, with their legal issues of handling genetic data in EMRs [21]. authors advocating the view that humans possess the Scheuner et al. conducted a case study to validate if rights of privacy and to protect those that do not want current EMR systems meet genetic information to know [13, 16]. Conversely, rapid innovations in needs [22]. This study shows an overall lack of genetic research require wide accessibility to many support for functionality, structure, and tools for genetic databases. The idea of open access in the clinical genetic practice. A more recent study of the field of genomic research is expressed in the state of EMRs supporting genomics for personalized Bermuda Principles and the Fort Lauderdale medicine identifies structure of data as a challenge Agreement, which has been applied in North [23]. Therefore, it is necessary to implement an America and in the UK for funded research [17]. informed consent management system in current Genetic research typically requires additional EMRs. metadata with genetic data sets, such as demographic details family relationships, medical history, etc. Some researchers suggested that the legislation These metadata elements can be exploited for tracing for generating and using genetic information an individual’s identity. properly is pivotal to improving genetic privacy [24]. In 2013, the Health Insurance Portability and In general medicine, an informed consent, Accountability Act of 1996 (HIPAA) [8] Omnibus especially informed privacy consent, provides the Rule included genetic information as PHI to be proper opportunity and knowledge for patients and regulated under the privacy portion of HIPAA. STIDS 2016 Proceedings Page 47 Nonetheless, states may have different definition of outcomes from the three levels (Federal, State genetic information. The combination of Federal and Organization) and provides a final result privacy laws along with the various state laws form for permitting or denying access. The outcome a fragmented regulatory and statutory landscape for includes the consolidated list of conditions for permissible information sharing and consent all three levels. For example, the list of consent management. To be valid, informed consents for clauses required by both the Federal genetic privacy must comply with these laws and regulations and organizational policies. regulations. Indeed, significant regulatory gaps The first component of implementing the genetic create additional burdens in providing automated privacy enforcement is to gather the required ways to obtain and generate information consent in information through the workflow. As the usage EMRs. scenario is executed (under the workflow engine) the meta-data required to determine the releasability of III. SYSTEM DESIGN data is gathered and passed to the consent service. We developed a functioning prototype that The consent service then creates the objects and addresses the various aspects for an automated and relationships in the ontology for evaluation by the integrated informed genetic information consent reasoner. Next the service retrieves the results and system. The prototype brings together the data calls our 3-level rule hierarchical algorithm. The gathered during interactions with the medical service determines if access is permitted and passes provider with the applicable laws, regulations and the access results back to the workflow engine. The policies to address the privacy issues specific to acknowledgment steps in the workflow display the genetic information. There are three components of results along with the decision source (specific law or the prototype as shown in Fig. 1: regulation referenced), the consent clauses, obligations to be enforced for information released, x Workflow to gather the information, display and the specific rules used in the ontology to generate the outcome and obtain acceptance from the the answer. user of the results and any pre/post conditions for using the data. To support the consent service, we developed an ontology to capture the various aspects of enforcing x A ontological rule-base that takes the data privacy laws and policies. As seen in the Fig. 2 the from the workflow, evaluates the applicable prototype requires four related data items. laws, determines prerequisites (such as consents and obligations), and decides on the x Requester: the person making the request to releasability of genetic data. access the medical information including their role, associations with a specific x A consent service that interacts with the organization, and information about this workflow engine and ontology to pass data organization, back and forth. The service includes the Rule Hierarchy Algorithm which combines the x Request: details on the purpose for requesting the information, and where the information will be used. The four purposes applicable to genetic information are disclosure, research, testing and treatment. The prototype currently implements the information disclosure component with the applicable specific instances for Self-Request by the Patient, Law Enforcement, etc. x Response: the results of the reasoner applying the appropriate rules along with a list of any obligations that must be enforced by the EMR Fig.1. Prototype Components and specific consent clauses that are needed for the associated approvals. (A subclass for STIDS 2016 Proceedings Page 48 Fig. 2. Genetic Privacy Ontology Federal Responses allows information about the specific access request. By definition, Federal HIPAA-specific requirements to be laws are at the top of the hierarchy, followed by State gathered.) laws, and then organizational policies. The hierarchy algorithm dictates how conflicts between laws and x Resource: the part of the electronic medical policies can be resolved based the decisions made at record being requested along with each level. information about the subject (or patient). The Resource instances can be used to categorize In order to address these potential conflicts, detailed levels of rules such as enforcing Federal and State laws have an override flag restrictions to specific parts of the genome associated with them in the ontology to indicate that can be used to identify individuals or whether lower level rules can change the answer. If grant permission to components used in two levels come to the same conclusion (both permit genomic medicine. access), the supplemental clauses and obligations are combined into one complete response. For example, The ontology does not need to contain all the HIPAA permits access to medical records for information from the EMR because the current focus treatment. In Georgia, there are additional obligations is on rules implementation. Many entities in the and consent requirements when the resource being ontology provide reference information such as the accessed is from genetic testing. organizational meta-data or a list of specific Consent Clauses that are not described presently. The Response structure allows both sets of answers to be passed back to the EMR for evaluation The Rule Hierarchy Algorithm evaluates the and execution. However, if the results were different, interactions between Federal and State laws, the previous answers are discarded in favor of the regulations and institutional policies. The access lower level requirements in order to resolve the evaluation is done at each level (Federal, State and inconsistency. For example, if Federal law permitted Organization) in the hierarchy that is applicable for access and allowed an override to the Permit decision, STIDS 2016 Proceedings Page 49 the organizational policy may come to a different For the Organization level, Line (18) determines if conclusion and set the response to Deny. there is an Organization result and whether there is a The Rule Hierarchy Algorithm follows: State result with a State Override flag set to true or there is no State answer. If (18) is true, then (20)-(24) INIT {resAns, resObl, resDec, resCl, resRule} to {fedAns, fedObl, fedDec, fedCl, fedRule} (1) adds the Organization variables to the Result IF fedOver = true THEN (2) variables, while (26)-(30) set the Results variables to IF stAns <> null THEN (3) the Organization results. At the end of processing IF stAns = fedAns THEN (4) (34) the Results variables are passed back to the resAns = resAns + stAns (5) workflow via the YAWL API. resObl = resObl + stObl (6) resAns = resDec + stDec (7) IV. SYSTEM IMPLEMENTATION resAns = resCl + stCl (8) resAns = resRule + stRul (9) The prototype was developed using the YAWL ELSE (10) (Yet Another Workflow Language) workflow engine resAns = stAns (11) with Java classes that respond to the YAWL event resObl = stObl (12) handlers to trigger the ontology processing and Rule resAns = stDec (13) Hierarchy Algorithm. As seen in Fig. 3, the consent resAns = stCl (14) workflow gathers additional information regarding resAns = stRule (15) END IF (16) aspects of the tasks being performed, the requester END IF (17) and the subject before executing a call to the Consent IF (orgAns <> null) AND (((stAns <> null) AND Service in the “Check Consent” step. A final step is (stOver = true)) OR (stAns = null))) THEN (18) provided for validating that the results are acknowledged before returning the response to the IF orgAns = resAns THEN (19) associated EMR. resAns = resAns + orgAns (20) resObl = resObl + orgObl (21) The first YAWL screen shown in Fig. 4 is for the resAns = resDec + orgDec (22) “Get Request Information” step in the workflow resAns = resCl + orgCl (23) process to describe why the request is needed, what resAns = resRule + orgRul (24) part of the medical record is to be accessed, in what ELSE (25) state the action is being performed and, for research resAns = orgAns (26) resObl = orgObl (27) purposes, whether the request is for an individual or resAns = orgDec (28) group. Each of the three Get steps have a similar resAns = orgCl (29) screen. The “AckPermit” screen in Fig. 4 shows the resAns = orgRule (30) results, pre and post-conditions for using the END IF (31) information, and an input box to enter in acceptance. END IF (32) For an implementation such as an integration with the END IF (33) OpenMRS, these YAWL screens will be replaced RETURN resAns, resObl, resDec, resCl, resRule (34) with others that will be embedded in the EMR product. In (1) the Result variables for the Answer, Obligations, Decision Source, Clauses and Rules are initialized to the corresponding federal variables, which were retrieved from Protégé. In (2) the Federal Override variable is evaluated to determine whether other rules are to be evaluated. If so, (3) checks for State answer existing and, if found, (4) determines if the Federal and State answer match. Lines (5)-(9) Fig.3. Genetic Privacy Workflow adds the State variables to the Result variables when the Federal and State match while (11)-(15) set the Results variables to the State results when there is no match. STIDS 2016 Proceedings Page 50 associated object properties to gather additional information on the Requester, Subject, Purpose and the Resource. (These values were all gathered and populated by the workflow and consent service.) For example, the Request instance is linked in the ontology to the associated Purpose using the hasPurpose object property. The appropriate Response instance (Federal, State or Organization) stores the outcome of the rule regarding whether access is permitted or denied, whether an override is allowed (Federal and State), the HIPAA Category (Federal), the specific law or policy that generated the result, any appropriate obligations and clauses (via hasObligation and hasClause object properties), and a rule number that maps to the SWRL rule. An example of the implementation is a request to access the Genetic Test Results resource for the Treatment purpose in Georgia. As seen in Fig. 5, there are two different aspects to the Request: establishing relationships to other objects with relevant information and specific data properties for this request. The first object property assertion links the request to the part of the medical record the requester would like to access. The next three object Fig.4. Workflow Screen Shots assertions link to response objects that will hold the access permission (permit/deny) and other Once the consent service is called and the results information associated with the rules for each level generated, the latter are displayed for validation by (Organization, State and Federal). The next two the user. EMR integration will allow some of the object assertions link indicate which person is the tasks, such as generating consent letters, to be subject of the request (generally a patient) and the implemented and enforced within the product. The purpose for accessing the medical record. The data Consent Service serves as the integration engine between the workflow/EMR and the ontology. The Java-based Consent Service is triggered by a YAWL event handler on the Check Consent workflow step. The service then gathers all the data from the workflow entries to create and populate the ontology instances including the data and object properties. The object properties link the instances such as establishing the makesRequest relationship between the Requester instance and the Request. Once the data has been populated in the ontology, the reasoner generates the responses and stores the information. The service extracts the response information for evaluation using the Rule Hierarchy Algorithm. The ontology is implemented using the Protégé platform with the laws and regulations (Federal and State) plus the organization policies enforced via Fig.5. Request Properties SWRL rules and the Pellet reasoner. The predicate of each rule uses the Request instance with the STIDS 2016 Proceedings Page 51 assertion states that the request is being made in the state of Georgia (“GA”). The first SWRL rule below as seen in Protégé addresses the Federal law for access under the Treatment purpose. makesRequest(?r, ?req), forPurpose(?req, ?pur), purposeDesc(?pur, "Treatment"), Fig.6. Federal Response hasResponse(?req, ?res), responseLevel(?res, "Federal") -> isAllowed(?res, true), The next part of the example below shows the canOverride(?res, true), hipaaCategory(?res, SWRL rule for the State response, the SWLR "Permitted"), decisionSource(?res, "HIPAA"), statements explained in Table II, and the response in hasRule(?res, 4) Fig. 7. In the SWRL rule, the predicate sets the In this example, location as Georgia and that the rule can be executed if the Federal response allows an Override. The x ?r is for the Requester for the Request predicate also retrieves an additional obligation for a x ?pur is the Purpose for “Treatment” Consent Agreement and the agreement must have text specific to Georgia. The State response then is x ?req is the Request being made for the set to allow access with no override and information Federal Level with the Treatment Purpose that the decision was based on Georgia Law. The x ?res is the Federal Response that is response is linked to an obligation for a Consent associated with the Request. Agreement and the consent clause with text specific to Georgia. The explanation for each of these SWRL statements is provided in Table I. isSelf(?r, false), makesRequest(?r, ?req), TABLE I. SAMPLE FEDERAL RULE inState(?req, "GA"), forResource(?req, ?resource), forPurpose(?req, ?pur), purposeDesc(?pur, SWRL Statement Explanation "Treatment"), resourceName(?resource, makesRequest(?r, ?req) Links Requester to the Request "GeneticTestResults"), hasResponse(?req, ?res), forPurpose(?req, ?pur) Links Request with the Purpose responseLevel(?res, "Federal"), canOverride(?res, purposeDesc(?pur, "Treatment") Restricts the rule to only execute for true), hasResponse(?req, ?resst), the Treatment purpose description responseLevel(?resst, "State"), oblName(?obl, Links the Request with a Response hasResponse(?req, ?res) to store answer "ConsentRequired"), clauseName(?clause, responseLevel(?res, "Federal”) Gets the Response for Federal level "GAGeneticConsent") -> isAllowed(?resst, true), -> isAllowed(?res, true) Sets access to true in Response canOverride(?resst, false), decisionSource(?resst, "GA_LAW"), hasObligation(?resst, ?obl), canOverride(?res, true) Sets override to true hasClause(?resst, ?clause), hasRule(?resst, 5) hipaaCategory(?res, Sets HIPAA category to Permitted "Permitted") decisionSource(?res, "HIPAA”) Sets the decision source as HIPAA hasRule(?res, 4) Sets the rule number to 4 When the Pellet reasoner finds a set of instances that matches the Treatment and Federal conditions, the rule is executed and the ?res data properties populated with the values indicated. As seen in Fig. 6, the Federal Response is updated with the final values. Fig.7. State Response STIDS 2016 Proceedings Page 52 In the State example, the additional instances used When the Pellet reasoner finds a set of instances are: that matches the Treatment for someone besides the Requester in GA for GeneticTestResults and the x ?resource is for the “GeneticTestResults” Federal response has Override set to True, the rule is part of the medical record executed and the ?resst data properties populated x ?r is the Requester associated with the with the values indicated. In addition, the ?obl and Request ?clause instances are associated with the response as conditions to accessing the record. x ?obl has the Obligation that ConsentRequired must be obtained for this V. CONCLUSION request Our prototype brings together the operational data x ?clause indicates the consent agreement in an EMR workflow for protecting genetic for the patient must include the information privacy with the applicable laws, GAGeneticConsent clause regulations and policies to provide a definitive and x ?resst is the State response associated with consolidated response for access and the associated the Request pre/post conditions for use. Currently, we continue to implement additional Federal and State rules, policies The explanation for each of these SWRL and regulations to develop a comprehensive statements is provided in Table II. repository and rule base. The following phase in the prototype will build upon these capabilities for TABLE II. SAMPLE STATE RULE Federal/State laws and regulation enforcement to SWRL Statement Explanation accommodate the policies and procedures for a isSelf(?r, false),) Verifies Requester is not the subject selected medical organization. The resulting makesRequest(?r, ?req), Links Requester for the Request prototype will demonstrate the overall capabilities needed to meet the medical community’s access inState(?req, "GA"), Verifies Request is for Georgia requirements while balancing the individual rights to forResource(?req, ?resource) Links Request with the Resource privacy and ownership of their genetic medical data. forPurpose(?req, ?pur) Links Request with the Purpose purposeDesc(?pur, Restricts the rule to only execute for the REFERENCES "Treatment"), Treatment purpose description resourceName(?resource, Verifies Resource request is for the [1] M. D. Ritchie, E. R. Holzinger, R. Li, S. A. "GeneticTestResults") Genetic Test Results Pendergrass, D. Kim. "Methods of integrating Links the Request with a Response to hasResponse(?req, ?res) check previous rule results data to uncover genotype-phenotype responseLevel(?res, Limits the previous Response to interactions." Nature Reviews Genetics 16.2. "Federal") Federal Verifies the Federal rule allows 2015. 85-97. canOverride(?res, true) overrides Links the Request with a Response to [2] A. H. Németh, A. C. Kwasniewska, S. Lise, R. hasResponse(?req, ?resst) store answer P. Schnekenberg, E. B. Becker, K. D. Bera, ..., & Gets the Response for State level to responseLevel(?resst, "State") store answers K. Talbot. "Next generation sequencing for oblName(?obl, Gets the Obligation for Consent molecular diagnosis of neurological disorders "ConsentRequired") Required using ataxias as a model." Brain 2013. awt236. clauseName(?clause, Gets the Clause for Consent Required "GAGeneticConsent") [3] C. Pihoker, L. K. Gilliam, S. Ellard, D. Dabelea, Sets the State response to access is -> isAllowed(?resst, true) allowed C. Davis, L. M. Dolan, ... & E. Mayer-Davis. canOverride(?resst, false) Sets the state Response to not allow "Prevalence, characteristics and clinical override by organization decisionSource(?resst, Sets the State response to reflect the diagnosis of maturity onset diabetes of the young "GA_LAW") decision source as state law due to mutations in HNF1A, HNF4A, and hasObligation(?resst, ?obl) Links the retrieved Obligation with the State response glucokinase: results from the SEARCH for Links the retrieved Clause with the Diabetes in Youth." The Journal of Clinical hasClause(?resst, ?clause) State response Endocrinology & Metabolism 98.10. 2013. hasRule(?resst, 5) Sets the rule number to 5 for reference 4055-4062. STIDS 2016 Proceedings Page 53 [4] W. W. Lowrance, & F. S. Collins. “Identifiability codified as amended in scattered sections of 26, in genomic research.” SCIENCE 317. 2007. 600- 29, and 42 U.S.C. 602. [10] D. Mascalzoni, A. Hicks, P. Pramstaller, & [5] A. L. McGuire, & R. A. Gibbs. "No longer de- M. Wjst. "Informed consent in the genomics identified." SCIENCE-NEW YORK THEN era." PLoS Med 5.9. 2008. e192. WASHINGTON- 312.5772. 2006. 370. [11] L. O. Gostin, & J. G. Hodge Jr. "Genetic [6] F. D’Abramo, J. Schildmann, & J. privacy and the law: an end to genetics Vollmann. "Research participants’ perceptions exceptionalism." Jurimetrics 1999. 21-58. and views on consent for biobank research: a [12] A. E. Prince and M. I. Roche. "Genetic review of empirical data and ethical information, non-discrimination, and privacy analysis." BMC medical ethics 16.1. 2015. 1. protections in genetic counseling [7] J. E. Lunshof, R. Chadwick, D. B. Vorhaus, & G. practice."Journal of genetic counseling 23.6. M. Church. "From genetic privacy to open 2014. 891-902. consent." Nature Reviews Genetics 9.5. 2008. [13] S. M. Liao. "Is there a duty to share genetic 406-411. information?." Journal of medical ethics 35.5. [8] The Health Insurance Portability and 2009. 306-309. Accountability Act of 1996 (HIPAA). Pub. L. [14] A. Lucassen, & J. Kaye. "Genetic testing 104-191, 110 Stat. 1936, codi_ed as amended at without consent: the implications of the new 42 U.S.C x300gg and 29 U.S.C x1181 et seq. and Human Tissue Act 2004." Journal of medical 42 U.S.C x1320d et seq. ethics 32.12. 2006. 690-692. [9] Genetic Information Non-discrimination Act of [15] American Society of Human Genetics Social 2008 (GINA). Pub. L. 110-233, 122 Stat. 883, Issues Subcommittee on Familial Disclosure. [16] ASHG STATEMENT Professional re-shaping scientific practice."Nature Reviews Disclosure of Familial Genetic Information. Am. Genetics 10.5. 2009. 331-335. J. Hum. Genet. 62 (1998): 474–483. [21] D. Mascalzoni, A. Hicks, P. Pramstaller, & [17] E. Sherlock. “disclosure of patient's genetic M. Wjst. "Informed consent in the genomics information without their consent- Is the "public era." PLoS Med 5.9. 2008. e192. interset" really a Sufficient Justification?.” [22] J. Belmont, & A. L. McGuire. "The futility Genomics Law Report. 2009. retrieved March 2, of genomic counseling: essential role of 2015, from electronic health records." Genome http://www.genomicslawreport.com/index.php/2 medicine 1.5. 2009. 1. 009/11/10/disclosure-of-patientsgenetic- information-without-their-consent-is-the-public- [23] M. T. Scheuner, H. de Vries, B. Kim, R. C. interest-really-a-sufficient-justification/ Meili, S. H. Olmstead, and S. Teleki. "Are electronic health records ready for genomic [18] J. Kaye, S. M. Gibbons, C. Heeney, M. Parker medicine?." Genetics in Medicine 11.7. 2009. & A. Smart. "Governing biobanks: Understanding 510-517. the interplay between law and practice. " Bloomsbury Publishing, 2012 [24] M. H. Ullman-Cullere and J. P. Mathew. "Emerging landscape of genomics in the [19] D. Hallinan, & M. Friedewald. "Open electronic health record for personalized consent, biobanking and data protection law: can medicine." Human mutation 32.5. 2011. 512- open consent be ‘informed’under the 516. forthcoming data protection regulation?." Life sciences, society and policy 11.1. 2015. 1. [25] M. Gymrek, A. L. McGuire, D. Golan, E. Halperin, & Y. Erlich. "Identifying personal [20] J. Kaye, C. Heeney, N. Hawkins, J. De Vries, genomes by surname & P. Boddington. "Data sharing in genomics— inference." Science 339.6117. 2013. 321-3 STIDS 2016 Proceedings Page 54