Annual Renewal – Might be Your Data Plan, Not Your IRB Submission.

July 8, 2021

According to the Harvard Research Data Security Policy (HRDSP), when a data plan is assessed by an Information Security Reviewer, an expiry date will be assigned to each submission in the Research Safety Application (also known as the “Safety” tab). Accordingly, researchers are responsible for renewing their data plan before the assigned expiry date.


Recently, the IRB office has been seeing researchers confuse the renewal of their data plan with their IRB submission. With the revised human subject protection regulations that took effect in 2019, many studies no longer have an annual renewal requirement.

So, before you submit that annual renewal, please do a double check on which submission the renewal pertains to (Data Safety Plan versus IRB submission) and which tab you are entering information in (Safety versus IRB).