> For the complete documentation index, see [llms.txt](https://sexytrees.savimbo.com/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://sexytrees.savimbo.com/appendices/edna-case-study.md).
# Case study: how we began working on proper consents for eDNA
This is a [bricolage](/foundations/bricolage.md) protocol; which means we are building it in public! Some pages are under construction — but check back soon its updating fast!
eDNA had a problem, and it was a doozy.
Environmental DNA (eDNA) is genetic material that organisms continuously shed into water, soil, and air; sampling and sequencing it lets many species be detected at once without trapping, handling, or harming any of them ([Power et al. 2023](https://doi.org/10.1002/edn3.497)). That non-invasiveness, low cost, and multi-species reach make eDNA metabarcoding one of the few biodiversity-monitoring tools well suited to remote, community-led field settings ([Kestel et al. 2022](https://doi.org/10.1016/j.scitotenv.2022.157556); [Bélisle et al. 2026](https://doi.org/10.1111/1365-2664.70253)).
The same sensitivity that makes eDNA powerful creates a serious ethical problem. Deep-sequencing eDNA workflows capture human genetic material — from the people living and working on the land being sampled — just as readily as the target species, a phenomenon termed *human genetic bycatch* ([Whitmore et al. 2023](https://doi.org/10.1038/s41559-023-02056-2)). This is not trace contamination: recovered human sequences can be of high enough quality to identify disease-associated variants and infer the genetic ancestry of nearby populations ([Whitmore et al. 2023](https://doi.org/10.1038/s41559-023-02056-2)), raising direct concerns about consent, privacy, surveillance, and data ownership ([Ram 2023](https://doi.org/10.1038/s41559-023-02072-2)). For Indigenous and local communities the stakes compound: genomic information can be swept into a biodiversity sample, deposited in an open-access repository, and become effectively permanent and uncontrollable — a textbook breach of Indigenous data sovereignty if collected without informed, ongoing consent ([Handsley-Davis et al. 2021](https://doi.org/10.1038/s41559-020-01351-6)).
### The chain of collaboration
The collaboration began with the observation that eDNA could capture identifiable human DNA ([WarīNkwī Flores](https://www.linkedin.com/in/wariflores/) from [Kinray Hub](https://www.kin-ray-hub.com/)) also known as human genetic bycatch (HGB). This was confirmed by eDNA scientists ([Kristy Deiner](https://www.linkedin.com/in/kristy-deiner-44021111/) from [SimplexDNA](https://www.simplexdna.com/)).
We were overwhelmed by the risks and weight of dealing with this problem. Over two years, we interviewed the top 3-5 eDNA companies and several academic experts operating globally and confirmed they both knew this and had not included consents, human ethics reviews, or practical controls in the lab for the storage of human DNA.
There was a financial reason for this, which representatives at these companies privately disclosed. eDNA libraries are rapidly evolving, and storing samples for later analysis allows reanalysis and expanded datasets, contributing to the per-sample value of retrieved Ecological genetics.
At the time, we were not working in eDNA and decided to pick our battles. Until we confirmed that, yes, we did have to [work with eDNA for agroforestry](/biodiversity-credits/calculation.md#edna-as-a-measurement-approach). Although by then, papers were being published on the problem, we reconfirmed with industry contacts that no one had developed an adequate consent form or had any plans to do anything about it.
Cleanup would have to begin with us. On our pilot site, with the advisors and legal expertise we had to hand. In other words, cleanup was going to be [bricolage](/foundations/bricolage.md).
### What each contributor brought
We worked with active labs to define what protocols were available for controlling human DNA analysis ([Kristy Deiner](https://www.linkedin.com/in/kristy-deiner-44021111/) from [SimplexDNA](https://www.simplexdna.com/)). Then consulted several international lega firms to see if any could help us with proper contracts. We could not afford the right legal teams, and none would do it pro bono. We tried to raise funds with over a dozen grant applications, and private requests for aid, and were also unsuccessful.
So we settled on legal experts with experience in medical consents to get proper consents defined for any human DNA ([Michael Nichols](https://www.linkedin.com/in/michaelgnichols/) from Nichols Law). Then involved academic scientists with experience in both eDNA and IDsov ([WarīNkwī Flores](https://www.linkedin.com/in/wariflores/)).
After drafting a consent, we sent it to several academic advisors for collaborative editing. This included ethics consults with our internal bicultural ethics panel. It was decided that the ethical risks of sampling without a consent, was higher than sampling with an early draft of a consent.
We drafted a consent that could be forked, cloned, and versioned on GitBook.
Local field staff worked with international researchers to practice doing informed consent in the field ([Santiago Romero](https://www.linkedin.com/in/santiago-r-2126b7328/), [Jeidy Caicedo](https://www.linkedin.com/in/jeidy-caicedo-ab9106378/), and [Karen Yulieth Serna](https://www.linkedin.com/in/karen-yulieth-serna-7721982a3/?lipi=urn%3Ali%3Apage%3Ad_flagship3_profile_view_base%3Bnu%2B2%2FSH3QoWEnacwUgpHYg%3D%3D))
#### **Figure X. Savimbo team and scientific collaborators doing eDNA sampling in the Colombian Amazon.**
### Why the chain worked
This is a bicultural problem. It's not enough to simply communicate the risk on the ground or control the sequences in the lab. The entire monetary and non-monetary value chain and data interpretation loop need to be connected, educated, and functioning across two very different cultural contexts.
We cannot emphasize enough the paradigm differences between the DSI commercial scouting going on with AI processing of lab data, and Indigenous communities parsing consent. These concepts must be simplified, translated into context (including metaphors), and the feedback is ongoing, not just one a time service.
We refer to the [data-steward + data-concierge model](https://www.savimbo.com/data#steward-concierge) as a practical way to facilitate community data rights within the context of a rapidly evolving technology situation. This relationship reduces harm and mitigates risk for all parties. Its inexpensive and has worked for us practically in multiple disciplines.
### What this protocol still needs
The data consents have been created, and tested with community communicators. The final contract will be loaded to GitHub and then available to fork and clone. The initial contract is very limited in scope, it only applys to laboratory situations where samples are destroyed. We are aware that there are extensive resources for storage and proper handling of human identifiable DNA but feel unqualified at the moment
* It's relatively easy to protect communities from active identification, its much harder to protect them from commercial exploitation.
eDNA sample contract (in development)
### The unanswered question
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