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Data & Research Ethics Policy

Last updated: November 2026 · Syntax of Life (Pvt) Ltd · Karachi, Pakistan

Biotechnology work is sensitive: it involves human samples, genetic data, regulated organisms and results that affect real decisions. This policy sets the non-negotiable rules for samples, data and research conducted through the Gateway, and forms part of our Terms of Service.

1. Scope

This policy applies to every RFQ, project, sample, dataset and deliverable handled through the Gateway — sequencing, bioinformatics analysis, multiomics studies and laboratory supply. It binds Customers, Providers, Suppliers and Syntax as platform operator.

2. Sample ownership and custodial duty

Biological samples remain the property of the Customer. A Provider in possession of samples acts as custodian: samples may be used only for the awarded scope of work, handled under documented procedures, and returned or disposed of as the project contract directs. Providers must not retain, sub-sample, re-test or transfer materials beyond the agreed scope without written authorisation.

3. Human samples — consent and ethics approval

Work on human-derived material is permitted only where the Customer holds valid ethics approval and lawful consent. By submitting an RFQ involving human samples you warrant that:

  • the study has been reviewed and approved by an Institutional Review Board, research ethics committee or competent authority as required in your jurisdiction;
  • donor informed consent covers the intended testing, analysis and any transfer of samples, consistent with the Declaration of Helsinki and applicable human-subjects rules;
  • samples shared through the platform are labelled and documented without direct identifiers unless the ethics approval expressly permits otherwise;
  • you can produce consent and approval documentation on reasonable request.

Providers must decline or flag work where documentation is missing or the scope exceeds the approval. The Gateway may suspend projects where ethical documentation cannot be produced.

4. Genomic and health data rules

4.1 Raw data stays off the platform

The Gateway does not host raw genomic files. FASTQ, BAM, CRAM and equivalent raw read data transfer directly between Customer and Provider under their contract. Platform attachments are documents only (≤25 MB), intended for reports, QC summaries and deliverables.

4.2 De-identification

Uploaded documents must not contain direct identifiers of donors or patients. Where pseudonymised data is used, the linking key stays with the Customer. De-identification standards consistent with HIPAA 45 C.F.R. §164.514 or GDPR anonymisation guidance are the accepted baseline.

4.3 Genetic data is special

Genetic information is inherently identifying — even de-identified sequence data can carry re-identification risk. Re-identification attempts, unauthorised secondary analysis, and using project data to build external datasets are prohibited. Aggregated, genuinely anonymised statistics may be used for platform reporting only where no individual or project is identifiable.

4.4 Secondary use

Results and raw data may be used only for the purpose the Customer engaged. Providers may not reuse, re-analyse, publish or monetise project data without the Customer's written consent.

5. Material transfer and shipping

Sample movement follows the project contract. Parties are responsible for lawful packaging, cold-chain where required, customs declarations and export/import permits. A Material Transfer Agreement (MTA) is recommended for regulated or high-value materials and may be required by a Provider's own compliance rules. Chain-of-custody events are recorded in the project timeline; disputes about shipment condition are resolved against that record.

6. Biosafety and dual-use

Work must be performed at the biosafety level appropriate to the material, under the provider's institutional biosafety approvals and applicable national rules (for Pakistan, the National Biosafety Committee framework and Pakistan Biosafety Rules). The following are prohibited on the Gateway:

  • work on select agents or controlled pathogens without the required permits;
  • gain-of-function or enhanced-pathogen research intended to increase transmissibility or virulence;
  • work intended for the development of biological weapons or other hostile applications;
  • transfers that violate export-control or sanctions law.

RFQs with dual-use indicators may be flagged for manual review. Syntax may request additional documentation, route to specialist review, or decline the request entirely.

7. Genetic resources and benefit sharing

Collection and use of genetic resources (plant, animal, microbial or environmental) must comply with the laws of the source country, including access and benefit-sharing obligations under the Nagoya Protocol where applicable. Customers must hold the permits and provenance documentation for samples sourced outside their jurisdiction, and must not use the platform to circumvent benefit-sharing duties.

8. Data lifecycle on the platform

  • Draft → release: result files upload as drafts visible to the performing Provider; they become accessible to the Customer only on release. Until released, file access is denied (HTTP 403) — a technical enforcement, not a convention.
  • QC records: intake QC verdicts (pass / partial / fail with measured metrics) are permanent project records; Customer proceed/resend/cancel decisions pause and resume the SLA clock.
  • Retention: project documents are retained per the project contract and our retention schedule (Privacy Policy §7); financial records follow statutory periods.
  • Deletion: valid deletion requests are honoured subject to legal holds; residual copies expire with backup rotation.

9. Data ownership and derived IP

The Customer owns project results, reports and their underlying data. Provider-developed methods, pipelines and general know-how remain the Provider's. Syntax claims no ownership over project content and uses it only to operate the marketplace and meet legal obligations.

10. Incident handling and complaints

Suspected misuse of samples or data, biosafety concerns, or unauthorised disclosure must be reported through the complaints process or contact page. We investigate, may pause the affected project, and will notify affected parties and regulators where the law requires. Providers and Suppliers must cooperate in investigations and preserve relevant records.