Below are some key points from the All of Us Research Program Data User Code of Conduct. The full agreement is available for download at the bottom of this page.

The Data User Code of Conduct describes how All of Us Research Program data can and cannot be used for research projects. For researchers, this includes but is not limited to agreeing to the following terms. As an “Authorized Data User” of the All of Us Research Program data, you:

• Respect the privacy of research participants at all times.
  • You will NOT use or disclose any information that directly identifies one or more participants.
• Use the All of Us data only for the purpose of biomedical or health research.
• Provide a meaningful and accurate description of your research purpose every time you create an All of Us Research Program workspace.
• Take full responsibility for any external data, files, or software that you import into the All of Us Researcher Workbench and the consequences thereof.
• DO NOT share your login information with anyone, including other authorized data users of the All of Us Research Program.
• DO NOT attempt to contact All of Us Research Program participants.
• DO NOT take screenshots or attempt in any way to copy, download, or otherwise remove any participant-level data from the All of Us Researcher Workbench.
  • You will NOT publish or otherwise distribute any participant-level data from the All of Us Research Program database.
  • You will NOT publish or otherwise distribute any data or aggregate statistics corresponding to fewer than 20 participants unless expressly permitted under the terms of the All of Us Data and Statistics Dissemination Policy.
• DO NOT redistribute or publish Registered or Controlled Tier data
• DO NOT attempt to link Registered or Controlled Tier All of Us Research Program data at the participant level with data from other sources.
• DO NOT use All of Us Research Program data or any part of Research Hub for marketing purposes.
• DO NOT represent that the All of Us Research Program endorses or approves of any research unless such endorsement is expressly provided in writing by the All of Us Research Program.
• DO NOT link Registered or Controlled Tier All of Us Research Program data at the participant level with participant-level data from other sources without the explicit, documented permission of the All of Us Research Program.

Full policy is available here:

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Below are some key points from the All of Us Research Program Data and Statistics Dissemination Policy. Data users should follow the full policy, available for download at the bottom of this page.

Under the All of Us Data and Statistics Dissemination Policy:

1. No participant count of 1 to 20 can be published or distributed directly (a count of 0 is permitted); and
2. No data or statistics can be reported that allow a participant count of 1 to 20 to be derived from other reported cells or information, including in text, tables, or figures. This includes the use of percentages or other mathematical formulas that in combination would allow an individual to deduce a participant count of less than 20.

This policy permits data users who wish to report data or aggregate statistics that correspond to fewer than 20 participants to obscure these values using scientifically accepted strategies, including collapsing data across cells, coarsening data, or cell suppression. More information about acceptable strategies and how to employ them are available in the Researcher Workbench.

Full policy is available here:

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Below are some key points from the All of Us Research Program Data User Appeals policy. Data users should follow the full policy, available for download at the bottom of this page.

The All of Us Research Program Data User Code of Conduct requires data users to establish a project workspace for each unique research project. Each project workspace, in turn, must bear a meaningful and accurate description of the research purpose that is created at the time of workspace initiation. These workspaces and descriptions are subject to review upon public or user request or during periodic audits of the Research Hub. The All of Us Resource Access Board (RAB) is charged with conducting any reviews necessary to determine compliance with the Data User Code of Conduct. The Resource Access Board shall do so, according to the policies and guidelines set forth by the All of Us Research Program. The RAB will determine whether the workspace project is compliant with the Data User Code of Conduct and recommend corrective or enforcement action. In some instances, data users may disagree with RAB determinations. In these situations, data users may appeal the determination according to the policy below.

Full policy is available here:

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Below are some key points from the Publication and Presentation policy. Data users should follow the full policy, available for download at the bottom of this page.

Researcher Workbench users are obligated to inform the program of any upcoming publications or presentations resulting from the use of All of Us Research Program data (including peer-reviewed manuscripts or conference abstracts) at least two weeks before the date of publication or presentation. You can do this by contacting User Support in your Researcher Workbench account. Your manuscript will not go through any program review. The information will only be used to allow the program to prepare for any media coverage or communication regarding the upcoming publication. Any embargoes will be honored.

Additionally, you must submit an electronic version of a final, peer-reviewed manuscript to PubMed Central immediately upon acceptance for publication, to be made publicly available immediately without any embargo period.

Researcher Workbench users must honor the contribution of those who take part in All of Us to the research project’s work. This includes in all oral and written presentations, disclosures, and publications resulting from any analyses of the data. The following is an example of an acknowledgement statement:

“We gratefully acknowledge All of Us participants for their contributions, without whom this research would not have been possible. We also thank the National Institutes of Health’s All of Us Research Program for making available the participant data [and/or samples and/or cohort] examined in this study.”

Full policy is available here:

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Below are some key points from the policy on Stigmatizing Research. Data users should follow the full policy, available for download at the bottom of this page.

The All of Us Research Program defines stigmatizing research as any research proposal, project, or question that has the potential to instigate or promote marginalization of, discrimination against, or loss of status by a person or group of people. Stigma may be inherent in the research design (e.g., the formation of a research question based on prejudicial biases) or a byproduct of the research findings (e.g., the interpretation of findings in a way that promotes negative stereotypes) and may be intentional or unintentional.

While complete elimination of stigmatizing research based on the use of All of Us data resources is likely impossible, the program takes steps in earnest to prevent resource use with the potential to stigmatize. Conduct of stigmatizing research using the All of Us data resources is prohibited, and the program reserves the right to penalize violators of this policy as appropriate.

Full policy is available here:

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The All of Us Research Program requires authorized users of the All of Us data to conduct research that follows and conforms to the ethical principles upheld by the program. This means that, as a user, you must:

• Know and follow all laws and regulations regarding research involving human data and data privacy that are applicable in the area where you are conducting research, including all applicable federal, state, and local laws.
• Know and follow the Common Rule principles as defined by The Belmont Report:
  • Respect for persons. Participants must be treated as individuals with the ability to consider and make choices about their participation consistent with their own interests and goals. Vulnerable populations are entitled to additional protections from human subject research. This includes children, prisoners, and women who are pregnant.
  • Beneficence. Researchers working with human participants must ensure participants’ well-being. Research should not intentionally harm participants, should maximize the possible benefits, and should minimize any potential harm.
  • Justice. This principle requires that the benefits and harms resulting from research be distributed fairly amongst people by using ethical inclusion and exclusion criteria. Researchers must ensure that people benefit from their research according to need and not affordability.
• Understand that non-human subject research can still cause psychological, social, and economic harm even if the risk for physical harm is low.
• Understand the effects your research results can have on communities and society.

Conducting ethically sound research thus affirms commitment to the core values of the All of Us Research Program by respecting the dignity and choices of participants as partners and actively considering the vulnerabilities and disadvantages of varied individuals and communities.

Full policy is available here:

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Below are some key points from the Policy on Respectful Research Involving American Indian and Alaska Native (AI/AN) Populations. Data users should follow the full policy, available for download at the bottom of this page.

In the interests of ensuring responsible and respectful use of All of Us research, operational, or other program resources (hereafter referred to as All of Us resources) originating from participants who self-identify, or may be otherwise identified, as American Indian or Alaska Native (hereafter referred to as AI/AN individuals), the All of Us Research Program has promulgated specific policy to direct authorized users of All of Us resources in the appropriate use of such resources. Under this policy, authorized users agree to abide by the following terms:

Acknowledgement: Authorized users acknowledge the scientific community’s past transgressions against tribes and AI/AN peoples and promise to conduct research that recognizes Tribal sovereignty and is respectful of applicable Tribal culture and customs. Encompassed in this promise is the pledge, on the part of authorized users, to go to great lengths to avoid further harms, including stigmatization. As such, authorized users:

• Must review and abide by the terms of the All of Us Data User Code of Conduct (and/or other relevant resource use agreements), the All of Us Policy on Stigmatizing Research, the All of Us Policy on the Ethical Conduct of Research, and all other data access and use policies.
• Must not attempt to re-identify AI/AN individuals or attempt to re-identify the region from which such individuals come or the tribe(s) to which they belong.
• Must be up-to-date on their Responsible Conduct of Research (RCR) Training, including any specific training modules necessary for the use of All of Us resources originating from AI/AN individuals in a manner that would reveal regional or Tribal information.
• Must agree to use respectful and appropriate language and preferred terminology when discussing AI/AN individuals and all information related thereto.

Legal Compliance: Authorized users must abide by all relevant federal, state, and local laws and regulations applicable to the research.

Non-Data Resources: When relying on use of biospecimens and/or direct participant contact mediated by All of Us, authorized users must abide by the specific terms and conditions of the relevant All of Us policy or policies.

Enhanced Oversight: Authorized users agree to additional scrutiny when research focuses on AI/AN or Tribal populations.

• Workspaces associated with such research may be subjected to more frequent audits by the All of Us Resource Access Board, which may engage ad hoc members who are subject matter experts and/or Tribal citizens for the purposes of such reviews.
• Violations of All of Us policies where the outcome of the violation may have bearing on AI/AN or Tribal populations, including AI/AN individuals and/or Tribal Nations, may be reported to the NIH Tribal Advisory Committee or other relevant oversight bodies and, as a consequence, may incur additional penalties.

Full policy is available here:

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