Audience: University of Michigan School of Nursing (UMSN) faculty, researchers, instructors, and project teams
This guide explains how to evaluate the use of institutional data with U-M artificial intelligence services and when to consult the Institutional Review Boards (IRBs), Information Assurance (IA), Privacy, Procurement Services, or other U-M compliance offices.
Key principle
Use institutional data only in an AI service, model, and workflow that U-M has approved for that type of data. Access through a U-M account does not, by itself, mean that every model or feature is approved for sensitive or regulated data.
Quick decision guide
- Identify the activity. Is the work research, teaching, clinical care, quality improvement, administration, or software development?
- Classify the data before entering it. Determine whether the material includes public, internal, sensitive, regulated, or restricted information.
- Confirm that the specific AI service and model are approved. Approval can differ by service, model, feature, integration, and data type.
- Check whether an existing protocol, agreement, consent form, or notice permits the use. AI use must remain consistent with IRB directives, participant consent, data use agreements, contracts, privacy notices, and sponsor requirements, and applicable law.
- Engage the appropriate U-M office before use when a trigger below applies.
- Use the minimum necessary data. Remove identifiers and unnecessary details, limit access, verify outputs, and follow applicable retention requirements.
Stop and consult before proceeding if:
- The data include protected health information (PHI), student education records, research participant information, credentials, export-controlled information, or other regulated data.
- The project involves human-subjects research or changes an approved research protocol.
- You want to purchase, subscribe to, integrate, or accept terms for a third-party AI product.
- The AI tool will make or materially influence decisions about care, employment, admissions, grading, student progression, or research participants.
- You are unsure whether the service, model, or feature is approved for the proposed data.
U-M AI services
U-M GPT
U-M GPT provides eligible faculty, staff, and students with access to multiple generative AI models. U-M GPT offers institutional privacy and security protections that are not necessarily available in public or individually purchased AI accounts.
- Use only models and features approved for the applicable data classification.
- Do not assume that approval for one model applies to every model available through U-M GPT.
- PHI may be used only in a U-M GPT model and workflow explicitly approved for PHI and only when all HIPAA, institutional, access-control, and minimum-necessary requirements are satisfied.
- Users remain responsible for verifying output, protecting data, and complying with research, clinical, educational, and administrative requirements.
See Artificial intelligence services from U-M Information and Technology Services.
U-M Maizey
U-M Maizey allows users to create AI experiences grounded in selected datasets. Before adding institutional content, dataset owners should evaluate the classification of the source material, user access, copyright and licensing, retention, and whether the collection contains regulated data.
See U-M Maizey in depth.
U-M GPT Toolkit
U-M GPT Toolkit provides API-based access for application development, automated workflows, and large-scale analysis. API use may create additional security, architecture, logging, access-control, and cost considerations.
Consult IA or the appropriate IT security contact before using Toolkit when a workflow:
- Processes sensitive or regulated data;
- Connects to another U-M or external system;
- Stores prompts, responses, embeddings, logs, or uploaded files;
- Uses service accounts, API keys, or automated agents;
- Provides AI output to patients, students, research participants, or the public; or
- Could materially affect clinical, academic, employment, or administrative decisions.
See U-M GPT Toolkit. Toolkit usage has associated costs.
Using institutional data
Institutional data include information created, received, maintained, transmitted, or used by U-M. Examples include student records, research data, patient information, personnel records, internal reports, unpublished course material, contracts, financial information, credentials, and licensed content.
Examples of data and recommended actions
| Data or activity |
Examples |
Recommended action |
| Public information |
Published websites, public reports, openly licensed literature |
Generally lower risk. Confirm copyright, licensing, attribution, and accuracy. |
| Internal information |
Draft policies, meeting notes, unpublished instructional material, internal reports |
Use an approved U-M service. Confirm that the information is not confidential, contractually restricted, or regulated. |
| Student information |
Names, grades, advising records, accommodations, clinical evaluations, identifiable student work |
Treat as potentially protected by the Family Educational Rights and Privacy Act (FERPA). Use only an approved service and consult Privacy, the Registrar, or IA when uncertain. |
| Research information |
Participant data, transcripts, recordings, study notes, coded datasets, genomic information |
Check the IRB protocol, consent language, data use agreements, sponsor terms, and security plan before use. |
| PHI or clinical information |
Medical record content, clinical notes, patient messages, images, dates of service, medical record numbers |
Use only a service, model, and workflow explicitly approved for PHI. Apply the HIPAA minimum-necessary standard and applicable Michigan Medicine or U-M health privacy requirements. |
| Credentials and security information |
Passwords, API keys, private keys, access tokens, system vulnerabilities |
Do not place credentials in prompts, code, files, or datasets. Contact IA if credentials or security-sensitive information are disclosed. |
| Contractually restricted or licensed content |
Publisher content, proprietary instruments, licensed databases, sponsor-owned data |
Review the license, contract, or data use agreement. Consult the library, Procurement Services, the Office of General Counsel, or the project’s contracting office as appropriate. |
De-identification does not automatically resolve every requirement
Removing names may not make a dataset anonymous. Dates, locations, clinical details, rare diagnoses, free-text narratives, images, device identifiers, and combinations of variables can identify a person. Coded data may also remain identifiable when a team retains a key.
- HIPAA de-identification requires an approved method; it is not achieved merely by deleting names.
- IRB requirements may continue to apply to coded or de-identified research data.
- A data use agreement, consent form, sponsor condition, or contract may prohibit AI processing even when direct identifiers are removed.
- Do not ask an AI model to perform the initial de-identification unless the model is approved to receive the original identifiable data.
When to engage U-M compliance and service offices
Consultation triggers
| Office or function |
Engage when |
Questions to prepare |
| IRB or Human Research Protection Program |
The activity is human-subjects research; AI use changes an approved protocol; AI will recruit, consent, interact with, analyze, classify, or make recommendations about participants; or you need a formal determination that an activity is not regulated research. |
What data will enter the system? Is it identifiable or coded? Was AI use described in the protocol and consent? Will a vendor retain data? How will outputs be validated? |
| Information Assurance |
The workflow uses sensitive or regulated data, APIs, system integrations, automated agents, external storage, custom software, service accounts, or a new vendor. |
What is the data classification? Where are data processed and stored? Who can access prompts, files, logs, and responses? What are the retention and deletion controls? |
| Privacy |
Personal information is collected or reused; individuals may not reasonably expect AI processing; the system conducts profiling or monitoring; or privacy notices and consent language may need revision. |
What personal information is involved? What is the purpose and authority for processing? Who will receive the output? How can individuals exercise applicable rights? |
| Procurement Services |
You want to buy or renew an AI product, start a trial, accept click-through terms on behalf of U-M, use a vendor plug-in, or transmit U-M data to a third party. |
What terms apply? Will U-M data be used to train vendor models? Are subcontractors involved? What are the breach, deletion, ownership, accessibility, indemnification, and termination provisions? |
| Michigan Medicine compliance, privacy, or security |
The activity involves patient care, clinical operations, Michigan Medicine systems, PHI, clinical decision support, or communication with patients. |
Is the tool approved for clinical use? Is a business associate agreement required? Will output enter the health record or influence care? Who provides clinical oversight? |
| Accessibility |
Students, employees, research participants, patients, or the public will use an AI interface or AI-generated content. |
Does the experience meet WCAG requirements? Is keyboard and assistive-technology access supported? Is an equivalent alternative available? |
| Export Controls |
The data, software, technical information, collaborators, sponsor, or destination may be subject to export-control restrictions. |
What technical information is involved? Where will it be processed? Can vendor personnel or systems outside the United States access it? |
| Office of General Counsel or contracting office |
There are questions about intellectual property, copyright, licensing, liability, records requests, contractual restrictions, or ownership of inputs and outputs. |
Who owns the source content? What vendor terms apply? Can the output be published, licensed, patented, or shared? |
Research scenarios
Analyzing interview transcripts
Confirm that the IRB protocol, consent documents, data management plan, and any data use agreement permit AI-assisted analysis. If transcripts contain identifiers, use only a service explicitly approved for that data. An amendment may be needed if AI analysis was not included in the approved protocol.
Drafting a manuscript or grant
Public or nonconfidential text is generally lower risk. Do not enter unpublished participant data, confidential peer-review material, sponsor-confidential information, or proprietary findings unless the service and workflow are approved. Verify citations because AI systems can generate nonexistent or inaccurate sources.
Creating synthetic data
Synthetic data can still expose source information or preserve identifying patterns. If identifiable or regulated data are used to generate the synthetic dataset, the source-data requirements still apply. Document the generation method and evaluate disclosure risk before sharing.
Building a research chatbot or participant-facing agent
Consult the IRB and IA before deployment. Address consent, safety monitoring, accessibility, data collection, retention, escalation to a human, model limitations, and how adverse events or inappropriate responses will be handled.
Teaching scenarios
- Course preparation: Faculty may use approved AI services to draft learning objectives, examples, or rubrics, but should verify accuracy, bias, copyright, and alignment with course standards.
- Student work: Do not upload identifiable student work, grades, accommodations, or advising information unless the service is approved for the information and the use is consistent with FERPA and course expectations.
- Grading: AI should not be the sole basis for a grade or high-impact academic decision. Faculty remain responsible for evaluation and should consider transparency, consistency, accessibility, and opportunities for human review.
- Clinical education: Remove patient information from case discussions unless the selected service is explicitly approved for PHI and the use is otherwise authorized. A fictionalized case must not contain a combination of details that identifies a real patient.
- Required student use: Check accessibility, privacy, cost, account requirements, and availability of an equivalent alternative before requiring an AI tool.
Minimum safeguards
- Use the least sensitive and smallest amount of data needed.
- Do not include passwords, API keys, authentication tokens, or private encryption keys.
- Verify that recipients are authorized to view both the input and output.
- Review model and feature settings, including file retention, sharing, connectors, plug-ins, and conversation history.
- Do not rely on AI output as authoritative without qualified human review.
- Check factual claims, calculations, quotations, references, and clinical content.
- Evaluate outputs for bias, stereotyping, fabricated information, and disclosure of sensitive information.
- Document consequential uses, including the model or service used, human review, and validation steps.
- Follow records-retention, litigation-hold, research-record, and data-deletion requirements.
- Report suspected data exposure or security incidents promptly.
Information to provide when requesting a review
Preparing the following information can help the reviewing office respond efficiently:
- Name and web address of the AI service, model, plug-in, or vendor;
- Purpose of the activity and intended users;
- Whether the activity is research, clinical care, teaching, quality improvement, or administration;
- Types and classifications of data involved;
- Whether the data contain direct identifiers, codes, free text, images, audio, or video;
- Where data, prompts, files, embeddings, logs, and outputs are stored;
- Who can access the data and output;
- Whether information will leave U-M systems or be accessible outside the United States;
- Vendor retention, deletion, and model-training practices;
- Relevant IRB protocol, contract, consent form, data use agreement, or sponsor terms;
- How outputs will be reviewed, validated, and corrected; and
- Whether the output will affect patients, students, employees, or research participants.
Authoritative U-M resources
Disclaimer
This guide supports preliminary decision-making and does not replace an IRB determination, security review, privacy review, procurement process, legal advice, contractual review, or Michigan Medicine policy. Requirements can change as services and models are updated. When guidance conflicts, follow the more restrictive requirement and consult the responsible U-M office.