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Consider taking specific measures in the SIEF to protect information that you consider CBI, but you nevertheless need to share with the SIEF to conclude on the substance sameness. You can, for example:
- Have confidentiality agreements that limit access to documents or other information to specific named persons, or departments; and
- Allow access to certain documents in a ‘reading room’ only (where copying is not allowed); and
- Agree to have certain documents reviewed and/or assessed only by a third party expert (independent consultant) or a trustee.
You can strengthen this by having additional personal confidentiality agreements for those who get access to the CBI documents.
As a minimum, you should specify to the other SIEF members that the information is indeed CBI and, therefore, you communicate it and it can be used only for purposes of the verification of substance identity under REACH.
For more information on CBI, see section 9 of the Guidance on Data-sharing (https://echa.europa.eu/guidance-documents/guidance-on-reach).