Pan American Health Organization · 1st edition, 2020
Ethics framework for public health authorities, researchers and clinicians conducting surveillance, research and care during COVID-19.
- Issuer
- Pan American Health Organization
- Edition
- 1st edition, 2020
- Audience
- Public health authorities, ethics review committees, researchers, clinicians
- Evidence
- Expert consensus based on existing WHO ethics frameworks
- Reviewed
- 19 Oct 2026 · GMJ
What this guideline says
GMJ summary
This PAHO guidance, developed by the Regional Program on Bioethics, addresses ethical issues in public health surveillance, research and communication during the COVID-19 pandemic. It distinguishes public health surveillance (which does not require informed consent but must protect privacy) from research (which requires ethics review and informed consent). The document emphasises that emergencies demand higher, not lower, ethical safeguards.
Key ethical principles include equity (ensuring disadvantaged populations are not disproportionately burdened), transparency (honest communication about uncertainty and priority-setting criteria), solidarity (rapid data sharing across borders), and responsibility (building capacity for future emergencies). Health authorities must provide accurate, comprehensible information to the public, explain uncertainty honestly, and justify resource allocation decisions publicly when systems are overwhelmed.
For research, the guidance requires rigorous but fast-tracked ethics review, informed consent (with exceptions only when unfeasible and risks are minimal), broad consent for future sample use, and immediate open-access sharing of results. Community consultation before research initiation is strongly encouraged to build trust and ensure studies address local needs.
Key points
For clinicians — doses and thresholds as stated in the guideline
- Public health surveillance during COVID-19 does not require informed consent but must safeguard privacy, maintain confidentiality, collect data respectfully, and provide transparent information about data collection purposes
- All human subjects research during emergencies requires prior ethics review committee approval; ethics review must be fast-tracked but rigorous, not relaxed
- Informed consent is required for all emergency research unless ethics committees waive it when: (a) obtaining consent is not feasible, (b) studies have important social value, and (c) studies pose only minimal risks
- Broad consent for future research use of samples and data should be strongly encouraged to facilitate pandemic research; future studies using these samples still require ethics approval
- When health systems are overwhelmed and cannot provide care to all (e.g. ventilators, ICU beds), health authorities have an ethical obligation to provide public justification of priority-setting criteria
- Research results, protocols, instruments, data and samples must be shared promptly through open-access channels without delay to inform public health responses
- Health authorities must communicate uncertainty honestly, avoid false certainty, explain that recommendations may change as knowledge increases, and provide the most accurate and complete available information
- Community consultations prior to research initiation are strongly encouraged to ensure studies address local needs, designs are acceptable to populations, and trust is built
From the guideline
Verbatim
“Human subjects research conducted during emergencies must be subject to higher, not lower, ethical safeguards.”
Editor’s perspective
Why this matters for Georgia and the region
Prof. Giorgi Pkhakadze, MD, MPH, PhD
Editor-in-Chief, Georgian Medical Journal · Chair, Public Health Institute of Georgia · WHO consultant, health and migration
As someone who has worked extensively with WHO on health system strengthening in Georgia, I recognise that this guidance addresses tensions we faced during COVID-19 between rapid response needs and ethical standards. The distinction between surveillance and research is critical for Georgian institutions—our National Centre for Disease Control conducts both, and clarity on when ethics review is required protects both the public and researchers. I would emphasise to South Caucasus colleagues the requirement for transparent public justification of priority-setting criteria when resources are scarce; Georgia's relatively recent universal health coverage programme means the public expects accountability in resource allocation decisions. The practical challenge will be ensuring our ethics review committees have capacity for genuinely rigorous fast-track review—speed cannot mean rubber-stamping, but our committees may need technical support and training to review novel emergency research designs effectively.
ORCID 0000-0001-7609-4515 · Perspective written for the GMJ Guidelines Library, 19 Oct 2026
Applicability
Georgia and the South Caucasus
For Georgia and the South Caucasus, this guidance is directly applicable to COVID-19 surveillance, research and care delivery. National programmes must ensure ethics review committees have fast-track mechanisms whilst maintaining rigour, particularly as research capacity in the region continues to develop. Health authorities should implement transparent communication strategies that account for linguistic diversity (Georgian, Armenian, Azeri, Russian) and varying health literacy levels. Given ongoing health system strengthening efforts and universal health coverage implementation in Georgia since 2013, the guidance on public justification of resource allocation criteria during system overload is particularly relevant. Regional collaboration for data sharing across Armenia, Azerbaijan and Georgia could strengthen outbreak response capacity.
Questions this guideline answers
Quick answers
Does COVID-19 surveillance require informed consent from individuals?
No. Public health surveillance does not require informed consent, but data must be collected respectfully, privacy safeguarded, confidentiality maintained to the extent possible, and the public informed transparently about the data collection purposes and protections.
Can emergency research proceed without ethics review to save time?
No. All human subjects research during emergencies must obtain ethics approval before studies begin. However, ethics review committees must fast-track the review process whilst ensuring rigorous ethical scrutiny—higher, not lower, safeguards apply during emergencies.
Can leftover clinical samples be used for COVID-19 research?
Yes, if individuals provided broad consent for future research use, or if the public was informed that anonymised leftover samples may be used for research. Such studies still require prior ethics approval, and ethics committees may require consent or assess if a waiver is appropriate.
What should health authorities communicate when scientific uncertainty exists?
Authorities must be honest and transparent about unknown information, avoid false certainty, be straightforward about the scope of uncertainty, and explain that recommendations may change as more data are collected and research conducted. People are owed the truth.
Related on GMJ
Interconnected resources
Dictionary of Public Health
GMJ News coverage
Quality & accreditation
Other guidelines on this topic
- Frequently asked questions for the management of health workers in response to COVID-19
- Rehabilitation considerations during the COVID-19 outbreak
- Information and criteria for prioritizing diagnostic tests for SARS-CoV-2 in order to address the procurement needs of health systems
- Requirements and technical specifications of personal protective equipment (PPE) for the novel coronavirus (2019-nCoV) in healthcare settings
- The COVID-19 Risk Communication Package for Healthcare Facilities
- Issuer
- Pan American Health Organization
- Type
- Procedures, manuals, guidelines
- Edition
- 1st edition, 2020
- Status
- Current
- Published
- 2020-01-01
- Languages
- English (original PAHO document)
- Scope
- Global, with focus on Region of the Americas
- Audience
- Public health authorities, ethics review committees, researchers, clinicians
- Licence
- CC BY-NC-SA 3.0 IGO
- Evidence
- Expert consensus based on existing WHO ethics frameworks
- Record history
- Created 19 Oct 2026 · updated 19 Oct 2026 · next check Apr 2027
Pan American Health Organization. Ethics guidance on issues raised by the novel coronavirus disease (COVID-19) pandemic. Washington, DC: PAHO; 2020. (PAHO/HSS/BIO/COVID-19/20-0008). Available from: http://iris.paho.org/xmlui/handle/10665.2/52091GMJ Guidelines Library records are original summaries written by the GMJ editorial team from the issuer’s published document and reviewed by a physician. They do not replace the full guideline. The document is the copyright of its issuer and is linked, not hosted. Spotted an error or a newer edition? Tell the Guidelines Desk.
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