The revised Common Rule adds new responsibilities to researchers and HRPP/IRB s regarding the communication of future use and sharing of data to prospective participants. The NIH data sharing requirement comes into effect in a few months. To what extent is this a new world of data to which we must adapt or is it more of an appropriate extension of our current practices handling of data? And, what must research teams and HRPP/IRBs think about and do differently to ensure successful implementation of these data requirements? The NIH’s All of Research Program will be discussed as an one use case of broad data collection, sharing, and consent processes with participants.