tures to protect the confidentiality of health information and should have in place appropriate strong and enforceable sanctions against breaches of health information confidentiality.

Access to specific expertise and enhanced general education are important, but the committee also observed that the human element of the research enterprise necessarily includes human potential for error and even malfeasance. Therefore organizations should complement and support the proactive strategies of expertise and education for better confidentiality protection with deterrents to wrongdoing. Such sanctions ought to be graded according to the offense (e.g., whether the incident was a simple mistake or an intentional violation) and should apply not only to researchers but to all employees of the organization.

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