GISAID’s Submission to CBD Notification 2017-037

GISAID's position on the use of digital sequence information
and its benefit to public health

GISAID appreciates the invitation by the CBD Secretariat to comment on any potential implications of the use of digital sequence information on genetic resources for the three objectives of the Convention and the Nagoya Protocol, as communicated in notification 2017-37 Ref.:SCBD/SPS/DC/VN/KG/jh/86500 of 25 April 2017.

The Global Initiative on Sharing All Influenza Data (GISAID) is widely recognized as an indispensable mechanism for sharing influenza genetic sequence data (GSD) that embraces not only the interests and concerns of the wider influenza community[i], but in particular recognizes the ownership interests of Data Providers, for example the retention of rights over any potential intellectual property associated with the digital sequence information.

The GISAID benefit sharing mechanism, addressed in the Database Access Agreement (DAA)[ii], was developed in cooperation with low- and middle-income countries, and industrialized nations alike, by both CBD Parties and CBD Non-Parties, as outlined in the paper by Elbe and Buckland-Merrett (2017) in Global Challenges. GISAID introduced its new concept to incentivize data sharing, with the objective to provide an alternative to the sharing of GSD via conventional public-domain archives (e.g. GenBank, EMBL-EBI, DDBJ), where access takes place anonymously and Providers’ rights are either unprotected, or forfeited, and where no mechanisms are in place to enforce scientific etiquette, such as acknowledgement or collaboration with Data Providers, or to lay the ground work for research collaborations and benefit sharing.[iii]

From its very beginning in 2008, GISAID has proven to outpace all other sharing platforms for GSD of influenza viruses, emerging as the critical go to resource for data used by the global influenza research community and in particular the biannual vaccine strain selection process[iv] of the WHO’s Global Influenza Programme and Global Influenza Surveillance and Response System (GISRS) that this year celebrates its 65th anniversary. 

The acceptance of GISAID’s sharing mechanism and role in global health security was first noted after its platform was launched, and countries, for example Indonesia, started to share H5N1 data through GISAID. It was hailed as a major diplomatic breakthrough at the time.[v] GISAID was also of key importance in the response to the 2009 influenza A(H1N1) Pandemic[vi], allowing all countries to readily follow the evolution of the new virus as it spread globally.[vii]  The confidence in GISAID was further illustrated in 2013 by the unprecedented immediate release of the GSD of Influenza A(H7N9) viruses from the first human cases, by the Peoples Republic of China.[viii],[ix]

While GISAID has now developed a successful track-record as an effective and trusted mechanism for rapid sharing of both ‘unpublished’ and published influenza dataii it is also often considered as a useful blueprint for international sharing of sensitive data in the management of other diseases and global challenges, in ways that might be helpful for CBD and Nagoya Protocol discussions around benefit sharing and digital sequence information.[x],[xi]  In this respect, the principles underlying the GISAID Initiative were found to be closely reflected in the seven key principles for Data Sharing in Public Health Emergencies, published by GloPID-R in March 2017.[xii]

After nearly 10-years of operations, GISAID continues to demonstrate that it is possible to publicly share GSD of influenza viruses openly, rapidly and responsibly, with a spirit that is commensurate to that of the Nagoya Protocol on Access and Benefit-sharing. Perhaps this is why the Health Ministers of the Group of Twenty leading industrialized and emerging economies (G20) recognized the importance of GISAID in regard to data sharing.[xiii] The GISAID approach to attribution, research collaboration, and benefit sharing, including identification of contributors and users of data, and monitoring of data use, can provide important lessons and insights for the CBD/Nagoya Protocol policy process now considering ways to achieve fair and equitable benefit sharing from the use of genetic sequence data.

GISAID is committed to the timely, ethical, equitable and transparent sharing of influenza data, and willing to assist the CBD Secretariat in its deliberations on this important topic.

[i] Shu, Y., McCauley, J. (2017)  GISAID: Global initiative on sharing all influenza data – from vision to reality. EuroSurveillance, 22(13) doi:10.2807/1560-7917.ES.2017.22.13.30494 
[ii] GISAID EpiFlu™ Database Access Agreement, Freunde von GISAID e.V. 
[iii] Elbe, S., and Buckland-Merrett, G. (2017) Data, disease and diplomacy: GISAID’s innovative contribution to global health. Global Challenges 1:33-46. doi:10.1002/gch2.101 
[iv] World Health Organization, Recommended composition of influenza virus vaccines for use in the 2018 southern hemisphere influenza season, September 2017 
[v] McDowell R. (2008) Indonesia Agrees to Hand Bird Flu Information to New Online Database, Associated Press, May 16, 2008 
[vi] Schnirring, L. (2009) Pandemic reveals strengths of new flu database. Center for Infectious Disease Research and Policy 
[vii] Butler D. (2009) Swine flu goes global. Nature 458(7242):1082- 3. DOI: 10.1038/4581082a 
[viii] Gao R, Cao B, Hu Y, Feng Z, Wang D, Hu W, et al. (2013) Human infection with a novel avian-origin influenza A (H7N9) virus. New England Journal of Medicine. 368(20):1888-97 DOI: 10.1056/NEJMoa130445 
[ix] The fight against bird flu (2013) Nature 496(7446):397. DOI: 10.1038/496397a 
[x] Yozwiak NL, Schaffner SF, Sabeti PC. (2015) Data sharing: Make outbreak research open access. Nature 518(7540):477-9. DOI: 10.1038/518477a 
[xi] Benefits of sharing. (2016) Nature 530(7589):129. DOI: 10.1038/530129a 
[xii] GISAID's Comments on the Global Research Collaboration for Infectious Disease Preparedness' Principles for Data Sharing in PHE, May 2, 2017 
[xiii] Federal Republic of Germany, Berlin Declaration of the G20 Health Ministers, May 20, 2017