The IRB application has a section that requires investigators to address data collection and how these data will be protected and stored. Encrypting electronic data may not be enough, as The Research Ethics Blog advises.
IRB applications need to address where are the data being stored and how are the data being stored.
The investigator's strategy and protection plan have to be stated for the IRB to evaluate. Also, the consent process has to include this as well.
See http://www.researchethics.ca/blog/2010/01/privacy-of-data-is-ongoing-concern.html for more details and contact HARPO with any questions.
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