Controlled Unclassified Information (CUI) Program Security & Requirements Plan

Sensitive identifiable human subject research data is regulated by the Federal Policy for the Protection of Human Subjects (also called the “Common Rule”). Among other requirements, the Common Rule mandates that researchers protect the privacy of subjects and maintain confidentiality of human subject data.

A human subject is defined by federal regulations as a "living individual about whom an investigator (whether professional or student) conducting research obtains (1) data through intervention or interaction with the individual, or (2) identifiable private information.”

“Identifiable” means the information contains one or more data elements that can be combined with other reasonably available information to identify an individual (for example, Social Security number, health care record).

Personally identifiable data is sensitive if disclosure of such data would pose increased social/reputational, legal, employability, or insurability risk to subjects.