/Docs/G/GA4GH/Accountability-Policy/Form/0.md
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Criteria should be defined for assessing the severity of a sanction, for example, first or repeat non-compliance; non-compliance not self-reported in a timely manner; sensitivity of data; or impact on data donors, data stewards, or vulnerable populations. Where repeated incidents occur at the same institution, it may be appropriate to apply sanctions both to individual researchers and to the institution. In assessing non-compliance, elements of procedural fairness should be respected, including transparent, fair, and independent adjudication, a reasonable opportunity for affected parties to be heard, and specification of circumstances where an appeal is possible (e.g., when substantial sanctions are applied).