Sensitive Information – Examples include, but are

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Research is defined as a systematic investigation designed to develop knowledge that can be generalized. If you plan to present or publish the work or otherwise share results of the study, it is probably research. Are you planning on presenting the data of the project on human subjects at an academic conference, publish the data in an academic journal, or use the human subjects research data in a master's thesis or doctoral dissertation ? If NO: your project is not considered research and does not require IRB review. If YES: your project is considered research and requires IRB review. It may however be EXEMPT. Note: If your project is not hypothesis­driven, does not use research protocols and methodologies, and the anticipated data are intended for publication of an article in a newspaper or magazine, no IRB review is needed. Note 2: If no public dissemination is planned at the time the data is gathered, but the possibility of future dissemination exists, you are STRONGLY encouraged and advised to submit the project for IRB review and approval before initiating the research project. Question 1: Do Classroom Projects Require IRB review ? Certain activities have the characteristics of research but do not meet the regulatory definition of research needing IRB review. Examples of activities that may not need IRB review are: Data collection for internal departmental, school, or other University administrative purposes (e.g. teaching evaluations, course evaluations) If your research is a class project or term paper and will not be presented at a conference or published in any form at any time. Reviews and Searches of existing literature and research involving a living individual, such as a biography, that is not generalizable beyond that individual. Use the following guidelines to determine if your activities in the classroom are subject to IRB review. IRB review is NOT required if all of the following are true: a. The project is limited to surveys/questionnaires/interviews/observations of public behavior directly related to topics being studied in an official college course. b. The above surveys/questionnaires/activities, etc. contain no sensitive personal questions or other personal information that could stigmatize an individual. *Sensitive Information – Examples include, but are not limited to (The University of Maine):
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Information relating to an individual’s psychological well being or mental health
Information relating to sexual attitudes, preferences, or practices
Information relating to the use of alcohol or drugs
Information relating to illegal behavior
Information that if released could reasonably place the individual at risk of criminal or
civil liability or be damaging to the individual’s financial standing, employability, or
reputation
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Information that would normally be recorded in a patient’s medical record and the
disclosure could reasonably lead to discrimination, stigmatization, etc.
c. No identifying information is recorded to link a person with the data such that it could reasonably harm the individual's reputation, employability, financial standing, or place them at risk for criminal or civil liability. d. The participants in the project are not from a vulnerable or special population. *Protected Populations – Examples include, but are not limited to (The University of Maine):
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Children/Minors (under the age of 18) (Exception – projects conducted in established or
commonly accepted educational settings involving normal educational practices. Contact
IRB office for guidance.)
Prisoners (now includes non-publicly available secondary data)
Pregnant women
Fetuses and products of labor and delivery
People with diminished capacity to give consent
Mentally or physically challenged individuals
e. The collected data does not leave the classroom setting, or if the project involves collecting data on an organization, agency or company, the data are shared only with that entity. Note: Participants must be free to consent and stop their participation, or remove themselves
from the study at any time. f. No Medaille College employee or student is receiving financial compensation for collecting, organizing, analyzing, or reporting the data. If not ALL of these conditions are met, or if your project does not fall into any of these categories, your project will require IRB notification and formal IRB approval before you can start with your project. The following are examples of projects that do require IRB notification but are exempt from IRB review. Nonetheless, formal paperwork needs to be submitted to the IRB prior to the start of the project since the decision on the exempt status is the sole responsibility of the IRB committee. The study of or comparison among instructional techniques, curricula, or classroom management methods. The use of educational tests (cognitive, diagnostic, aptitude, achievement), survey procedures, interview procedures or observation of public behavior, unless this involves any one under the age of 18. The collection or study of existing data, documents, records, pathological specimens, or diagnostic specimens, if these sources are publicly available or the information is collected in a way that cannot be linked either directly or through identifiers to an individual. Question 2: Do Pilot Projects Require IRB review ? Pilot projects are preliminary investigations performed to determine if a study is feasible. The purpose is to refine data collection procedures and research design on a small scale. The questions asked usually do not contribute to generalizable knowledge and as such do not qualify as research and do not need IRB review. Exceptions that require IRB approval PRIOR to the start of the pilot project: Vulnerable populations, methods with more than minimal risk, or sensitive data will be used. The possibility exists that the collected data will be used in some form or another for publication purposes Question 3: Does "Existing Data" Analysis require IRB review ? Existing data are also called Secondary data. Such secondary data analysis involves using existing data from others sources to answer new questions. IRB review and approval is NOT needed if the source of the data is public (data from public libraries or newspapers) and analysis of the data will not make the data individually identifiable IRB review and approval IS needed if the source of the data is not public (government and private data bases) the existing data has not previously received IRB approval. Question 4: Do Internet/Online based projects require IRB review? If the data collected via the Internet and computers involves human subjects and is intended for eventual publication purposes, then it requires IRB review and approval. All such studies involving internet technologies must ensure compliance with the principles of voluntary participation and informed consent, the anonymity and confidentiality of the participants, and address the potential risks to the human subjects involved. Question 5: May a researcher who is teaching a course conduct research on students enrolled in his
or her class (es)? (Claremont Graduate University)
If an instructor at any grade level wishes to recruit and involve students in his or her own classes
in a research activity which will directly benefit the instructor (a dissertation research project, for
example), the instructor should consider the following guidelines and premises that will govern
IRB review of the research activity.
Instructors are in a position of authority over students in their classes, especially the power to
determine a course grade. This compromises the absolute requirement that participation in
research be voluntary, laying a veil of potential coercion over any in-class recruitment,
regardless of how benign the instructors’ intentions might be. It is therefore always preferable
for an instructor to recruit student subjects from the general student population if possible (e.g.,
advertise in student-oriented media, post on campus bulletin boards, list-serves, or
websites, broadcast to email addresses, etc.) or from classes or courses with which the instructor
is not involved in determining grades.
If circumstances dictate that there is no good alternative to recruitment of one’s own students
(and “it is so much easier to use my own classroom” does not equate to “there is no good
alternative”), the major protection against the appearance and potential of coercion is
maintaining the strict anonymity of participation—that is, the instructor must be insulated from
knowing the identity of students who engage in the research versus those who do not. If this is
not possible, then recruitment of one’s own students for one’s own research—or any research in
which the instructor stands to gain a personal benefit--is simply not permissible.
Provision of incentives to students for participating in research activities, such as extra credit or
bonus points toward a classroom grade, must be carefully considered in light of the requirement
for anonymity. The Board recognizes the practice of incentivizing participation with a modest
level of academic credit as a reasonable means of encouraging student participation in research.
However, alternative opportunities to achieve the same extra credit based on a comparable
commitment of effort to that required for the proposed research activity must be offered to any
student who prefers not to participate in the research.
Extra credit may be offered only if it can be arranged such that the instructor/researcher is
blinded to the identity of research participants versus nonparticipants who seek the credit through
an alternative activity. This may be arranged by interposing a neutral third party or technological
buffer in the credit confirmation process.
Final Considerations 1. ALL research with children, including adolescents, must be reviewed by the IRB committee. Children are considered a vulnerable research population. They are less able to give fully‐informed consent with respect to the research involved. Safeguard procedures and considerations are, therefore, required by the Federal regulations for the review of research involving children. In almost all cases, written consent from a parent or legal guardian must be obtained if the research involves children under the age of 18. 2. Even in the case where a project is not subject for review, the instructor/faculty member is responsible to uphold all applicable (e.g., American Psychology Association, American Counseling Association, National Institute of Health, etc.) ethical standards and guidelines in course‐related research activities when it comes to the treatment of human subjects. 3. It is the responsibility of the supervising instructor/faculty member to determine whether projects are subject to review. It is always best to err on the safe side and seek consultation from the IRB committee if a question arises regarding human subjects, research and classroom activities. 
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