Honest Broker Guidance


This page provides information about how to become a certilfied honest broker and how the investigator obtains permission to use a certified honest broker system.

  • An honest broker is a neutral third party, who is not part of the research team in any way. The honest broker cannot be one of the investigators or study coordinators, and cannot serve as a co-author on any publication.
  • Honest Broker Systems are set up for divisions, departments, clinics, labs etc. There are multiple honest broker systems throughout UPMC and Pitt.
  • An honest broker must have normal access (as part of their job responsibilities) to the data, records, specimens, etc that they will be obtaining and de-identifying. An honest broker is an individual, or system, acting on behalf of the researcher to collect and provide de-identified information/samples to the research team. In most cases, the honest broker systems are set up to obtain and provide clinical/medical records, data and specimens.

How to become a certified Honest Broker:

  • The Honest Broker application must be completed, signed, and submitted to the IRB for both the IRB and UPMC Privacy Officer to review and approve. Refer below to the application form and UPMC policy.
  • One individual must take responsibility for the honest broker system. More than one individual may be listed as honest brokers on the system. Once approved, the systems can be modified to add and remove individuals/brokers.
  • All Honest Brokers are required to complete CITI Research Ethics and HIPAA training before accessing the data. Refer to the required training as noted below.
  • Any listed honest broker(on an honest broker system for UPMC records/data) who is not a UPMC Employee must document how he/she is part of the UPMC workforce and have a UPMC employee as a supervisor.

How to request permission to use a certified Honest Broker:

  • The investigator wishing to use an honest broker system should contact the honest broker system and request honest broker services for their research study.
  • The Honest broker needs to agree to provide services and sign the honest broker assurance form. The investigator then submits to the IRB and provides the signed honest broker assurance form in their OSIRIS submission to the IRB.

If you have any questions email us askirb@pitt.edu.

Links to the documents for Honest Broker Certification Process:

  • UPMC Policy HSEC1807 (formerly HS-RS0002) and Data Use Agreement for Limited Data Sets  (PDF)
  • Application for Certification of Honest Broker Systems (Word)

UPMC Policy on PHI for Research

Use and Disclosure of Private Health Information (PHI) for Research Purposes Pursuant to the HIPAA Privacy Rules: UPMC Policy HSEC1611 (formerly HS-RS0001) (PDF)

Required Research Ethics and HIPAA Training

Three CITI (Collaborative Institutional Training Institute) courses must be completed before an individual can serve as an Honest Broker.  Follow the instructions displayed on the Pitt CITI portal at www.citi.pitt.edu. The IRB requires the following modules:

  1. Responsible Conduct of Research
  2. Human Subjects Research (Biomedical Course)
  3. Privacy & Information Security - This course replaces the ISER HIPAA Researchers Privacy Requirements (Formerly RPF Module 6).