JMIR Publications

ABSTRACT

Secondary use is now the ordinary course for data and biospecimens in health research. Clinical records collected for care become training data for prediction tools; archived images become foundation models; legacy biospecimens become renewable cell lines; and large corpora are repurposed to build health-related language models. Governance nevertheless continues to privilege the most obvious signals of persistence such as provenance logs, repository approvals, broad-consent forms, locality-preserving architectures, and documented ingestion pipelines, as if they were sufficient to establish legitimacy. They are not. In this article, we define the Continuity Trap as a continuity-specific form of proxy closure: a review-stage governance error in which a salient continuity signal in one domain is treated as sufficient reason to stop inquiry into whether semantic, authorization, and relational continuity have also been preserved. The concept is narrower than generic proceduralism, ethics washing, or proxy failure, because it isolates a specific inferential mistake in secondary-use review; and it is distinct from Goodhart’s and Campbell’s laws, which describe the dynamic corruption of measures once they become targets. The Continuity Trap can occur at an earlier stage, even in good-faith review. Continuity of ethical governance in data science health research must therefore be assessed across four domains, provenance, semantics, authorization, and relational standing, that we previously developed in our Representational Veracity framework. These domains can diverge as data are linked, transformed, modeled, and redeployed. We use vignettes from polygenic risk scores, legacy induced pluripotent stem cell derivation, federated learning, and health-related large language models to illustrate the problem. The policy implication is not universal re-review, but triggered continuity review whenever visible continuity is likely to be overread.