I. Introduction
II. Main Structures and Features
1. Key Features
III. Discussion
1. Governance
1) General concept
2) Requirements for inter-agency governance
2. Broad Consent
1) General concept
2) Advantages and limitations
3) Requirements for broad consent
(1) Educate and inform participants: The consent process must clearly define and explain the project’s purpose, the information to be collected, associated risks and benefits, privacy considerations, compensation, and withdrawal procedures. The consent form should use plain language to ensure full comprehension. Some terms—such as clinical information and medical records—may require additional clarification, necessitating professional training for those responsible for obtaining consent. Detailed information on risks, benefits, privacy, compensation, and withdrawal procedures must comply with legal requirements (BSA Articles 37, 38, 42, 43) [20–24] (Supplementary Tables S1 and S2).
(2) Clear consent for secondary use: The HDBB may provide and utilize data only after fully explaining the scope, methods, and procedures for secondary use. The NIBDCP consent form describes data collection, use, and provision methods at the time of initial consent. However, for secondary or tertiary use, issues such as privacy, compensation, and procedures for consent withdrawal must be addressed, and participants must be clearly informed that their data may be used for such purposes [25–29].
(3) Recognition of itemized opt-outs: The BSA grants participants the right to withdraw consent for research on human remains (Article 37), removal (Article 42), and genetic testing (Article 51), although it does not specifically address itemized revocation. The PIPA Enforcement Decree (Article 37, PIPA Enforcement Decree Article 44) stipulates that the withdrawal process should be (1) as easy as the collection process, (2) easy to understand, and (3) transparently described on the project website. Itemized revocation is allowed, and the Secretariat may require a participant’s contact information to verify withdrawal [30].
(4) Process for Consent from Minors: Under the BSA (Article 16-2(2)) and the Child Welfare Act (CWA; Article 3(1)), individuals under 18 must provide consent through a legal representative (BSA; Article 16, CWA; Article 3, PIPA; Article 22-2). The BSA also states that, if the donor of human derivatives is incapacitated, the legal representative must provide consent (BSA Article 37-2). Informed consent for minors and incapacitated individuals must ensure consistency between the intentions of the legal representative and the data subject. If participants aged 14–18 disagree with their representative, a separate review is required, as the PIPA defines children as under 14, whereas the CWA defines them as under 18.
(5) Enhancing Convenience: The consent process must be user-friendly, ensuring participants can easily understand and access the process. The NIBDCP employs electronic consent, which the Digital Signature Act (DSA) recognizes as equivalent to written consent. Consent documents may be securely stored in the cloud, if necessary. The “state-of-the-art principle,” used in US jurisprudence, supports the adoption of effective, cost-appropriate methods to enhance convenience.
3. Data Production
1) General concept
2) Requirements for systematic and sustainable data production
(1) Commitment to maintenance of data quality: Ensuring high-quality data is vital for the sustainability of the NIBDCP, as both the Databank and Biobank collect and link diverse information. In Korea, the establishment of the Korea Research Institute of Bioscience and Biotechnology in 1995 marked the beginning of efforts to create a microbial resource bank. These efforts were further formalized with the enactment of the Bioresearch Resources Act (BRA) in 2009, which regulates the distribution and disclosure of biological research resources [32,33]. Building on this foundation, Korea has prioritized data standardization and quality control through initiatives such as the National Biobank and the Korea Biodata Station under the KDCPA. To ensure the success of the NIBDCP, it is essential to strengthen the institutional and technical frameworks that support data production and utilization [1].
(2) Commitment to data standardization: Data standardization is crucial for ensuring the universality and interoperability of collected data. The BRA mandates standardization in the collection, preservation, and transmission of BRA (Article 18). Similarly, the Public Data Act (PDA) promotes the standardization of public data (PDA Article 13-2.12). To ensure high-quality data collection and production, both the Databank and Biobank must comply with the standards outlined in the BRA, PDA, BSA, and PIPA [34].
4. Data Provision and Utilization
1) General concept
(1) Provision and utilization of data in the databank: The MHW classifies data into four tiers for review under BSA procedures. Tier 1 includes anonymized summary statistics and clinical codebooks, downloadable by anyone via the web portal. Tier 2 encompasses educational datasets, which are available for download with monitored access. Tier 3 includes data with identification risk, which requires IRB and Data Review Board review for access. Tier 4 contains high-risk data; only analysis results may be exported after internal network analysis [19]. Tiers 1–3 focus on the disclosure of data with no or low identification risk, while Tier 4 prioritizes the protection of data with high identification risk. Data from Tiers 1–3 can be used but may not be redistributed by third parties (such as researchers and research organizations) [19].
(2) Provision and utilization of human resources information in the biobank: Researchers must submit a usage plan for human resources information to the Director of the KDCPA National Biobank, in accordance with the BSA. The Biobank reviews these plans and provides data following BSA and IRB guidelines. If consent is given by the data subject, the Biobank anonymizes and shares the data with third parties according to BSA regulations (BSA Article 43-2). Human resources information is shared with researchers only after anonymization, ensuring the integration of personal information and identification status within the Databank’s participant management system. If additional genetic testing or data production is required for the Databank’s genomic data plan, participants are notified via telephone, email, or web service and requested to proceed (BSA Article 43-2).
2) Requirements for data provision and utilization
(1) Establish data openness principles: To maximize data utility for research, data must be provided according to tiered openness principles. Tiers 1–3, which have low identification risk, should be as open as possible. Tier 1 comprises a general population cohort (chronically ill) with low-sensitivity data, provided after reviewing the resource–project link. Tier 2 includes clinical data (e.g., data from colorectal cancer patients) and requires review of both the resource–project link and sample size. Tier 3 involves highly sensitive clinical data (e.g., from patients with rare diseases or autism) and requires review of the resource–project link, sample size, and data capacity [35].
(2) Appoint a single IRB to increase accessibility for researchers: The BSA requires IRB review for human subjects and biomaterials research. However, variations in IRB procedures across institutions can cause delays and inconsistencies. For efficiency, a single IRB should be appointed, as permitted by the BSA and its Enforcement Rule (BSA Article 12-2), which allows the performing institution to select an IRB for collaborative research. This necessitates developing standards to address IRB discrepancies and create unified operational rules.
(3) Meet researchers’ data demands: Data production and delivery should align with researchers’ needs and current research trends. Real-time data status, utilization, and provision procedures must be developed to address these requirements.
(4) Simplify the data utilization process: To improve accessibility, the process for applying for and using data must be streamlined. Criteria for data use should be clearly defined, and applications for data provision should be standardized with key items specified.
(5) Demonstrate continuous commitment to data quality maintenance: Maintaining high data quality through ongoing data return is critical for the effective operation of the NIBDCP’s HDBB. The US National Institutes of Health’s Data Sharing Policy (2003) and Genomic Data Sharing Policy (2014) set clear standards for research data deposit. These standards should be harmonized with related laws, including the 21st Century Cures Act (2016), the Evidence-Based Policy Act (2018), and the Innovation, Competition, and Bioeconomy Research and Development Act (2021).



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