Updates to the OHS Access Policy
Jun 8, 2026 // Study Updates
OHS Access Policy (v3) updates
In March 2026, the OHS released an updated Access Policy. It revises existing sections and adds content to better support current and future Applicants and Approved Users of OHS Data and Biosamples.
All potential Applicants should review the Access Policy before requesting access. Key updates are summarized below.
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Major Changes | Other Updates | Biosample Request Guidance
Major changes:
- Longer renewal periods: access renewals can now be requested for up to three years at a time, instead of one. Provide justification and request only the time needed to complete the project. (Section 4; Section 7e)
- Streamlined approval and reporting for CanPath-approved requests involving OHS Data (Section 8e):
- If CanPath approves a project that also requests OHS-only data, a separate OHS Data and Biosample Access Application is not required.
- An OHS Data and Biosample Access Agreement must still be signed with the Approved User’s Host Institution, and fees must be paid before release.
- Some CanPath reporting forms, such as the Annual Progress Report, may be accepted instead of OHS forms. Approved users must submit their completed CanPath forms to the OHS.
- See Section 8e for details.
- Updated archival period: OHS Data may now be archived for up to one year after the Final Report is submitted. If a longer archive period is required, the OHS will hold the archived copy for the remaining time. (Section 13)
- Following this updated archival period, the Certificate of Destruction is due within one year of project completion, based on the Final Report submission date. (Section 7h; Section 13)
- Approved Users who generate Derived Data from Biosample analyses will have one year of exclusive access from the date the Derived Data are reported in an Annual Update. The Derived Data and supporting documents must be submitted to the OHS regardless of whether the analyses are published. (Section 4; Section 11)
- Applications from commercial or private-sector groups conducting health research may now be accepted and will be considered on a case-by-case basis. (Section 5b)
- Publication Policy updates (Section 10):
- Published results must use cell sizes of 5 or more, in line with ICES requirements.
- Submit manuscripts to the OHS at least two weeks before journal submission.
- Submit presentations to the OHS at least one week before the presentation date.
- Contact the OHS for the latest acknowledgement wording; consult other data custodians, if applicable, if additional language is needed.
- OHS Data and Derived Data cannot be shared with repositories. The policy includes wording for responding to repository requests.
Other updates:
Several sections with expanded and new content may also be of particular interest. Section 6 includes updated guidance on safeguarding Data and Biosamples, as well as a new subsection on how Incidental Findings will be handled. A new subsection for the Amendment Form explains its purpose, when to submit it and how amendment requests are handled in different scenarios (Section 7i). For future Applicants, the description of the access request review process has been expanded in Section 8b, as well as expanded guidance for Biosamples requests, listed below.
Biosample request guidance:
- Approved Users must ensure service providers and commercial labs comply with the Data and Biosample Access Agreement, or an equivalent supplemental agreement, including privacy, confidentiality, and data destruction requirements. (Section 6a)
- Expanded guidance on review considerations for Biosample requests (Section 8c):
- Added guidance on evaluation of Biosample requests, including favouring requests proposing methods such as multiplex assays to reduce volume or have sufficient justification for requesting high volumes proposing analytes not previously measured in the same Biosample set, and proposing methods with high probability of accurate results,
- Added restrictions on Biosample requests involving testing methods or lab equipment, and pilot studies. Requests inconsistent with OHS goals are not permitted. Discovery research may be permitted with sufficient justification.
- Prohibited uses include experiments involving humans, or in contact with cells or other materials to be infused into humans; animal research, and research using recombinant DNA.
- Added general information on coordinating biosample transfers.
- Approved Users are responsible for packing, shipping, return shipping, required permits, and applicable taxes. (Section 15)