The following email was sent out on Dec. 8, 2004. The upshot is that if you are just doing an investigation to enhance your learning and the learning of other students in the class, your investigation is not subject to instituional review by the IRB. This is a good thing, because it removes significant delays that you might have faced in previous semesters.
However, you are still responsible for following ethical guidelines for the study of your online community. As with many ethical issues, things are not always as clear-cut as they might seem. That's why we're having online discussion this week of two perspectives on the ethics of studying online communities. I strongly encourage you to go through the
PEERRS∞online training on human subjects protection.
A few guidelines follow for observation and interaction in your on-line communities.
First, you should be honest about what you're doing. If you become a member of a community you're going to study, people who interact with you should know that you're a student and that you're studying the community as part of the class. Often there's a personal profile page of some sort, but if not, or if you think people interacting with you won't read that profile page, you should indicate in your first message to anyone in the community something about what you're up to. Either in your profile page within the community, or on a web page somewhere else, you should probably have a place where you report to the community something about your methods, including whether you are going to quote people and how you're going to attribute any such quotes (by name, by pseudonym, or not at all).
Second, you need to respect privacy and autonomy of community members. If the activity is all carried out on a public site that is publicly indexed, then people should not have an expectation of privacy, but if there is restricted access, then you need to negotiate terms of how you can use the information at the time that you ask for access. If something seems potentially sensitive, ask before you use it, and don't use it if you're told "no."
You should also provide feedback to the community about what you're finding. This need not be everything that you report to the class, but there should be some benefit to the community being studied in terms of an opportunity to see itself through your eyes.
All of your communications, including the feedback you provide, should follow the communication norms of the community. Don't spam people with consent requests or reports about your observations if they consider that to be a nuisance.
If you're not sure about something, please raise the issue with the instructors, or on the class email list, before you do anything that is potentially harmful.
And if you're planning to publish something based on your investigations, then it *is* research, and you would have to follow the usual IRB procedures. In any case, please be sure to
Provost Courant and Vice President for Research Fawwaz Ulaby are
announcing to the School of Information faculty the following policy
statement, which addresses whether and when classroom assignments
should be reviewed by Institutional Review Boards (IRBs) to ensure
the protection of human subjects.
In support of its teaching mission, the University encourages novel
and innovative classroom activities. Some faculty design class
assignments that involve questionnaires, interviews, or other
interactions with individuals, such as those commonly used in
research methods courses. This memo addresses whether and when such
assignments should be reviewed by Institutional Review Boards (IRBs)
to ensure the protection of human subjects.
The purposes of this memo are:
1. To clarify when student class assignments fall under the
jurisdiction of the Institutional Review Board (IRB),
2. To describe how to seek approval from the IRB when the assignment
is under the jurisdiction of the IRB,
3. To underscore the obligations of instructors to consider and
mitigate potential risks to individuals affected by class assignments
even they are not under the IRB jurisdiction.
Student class assignments include those conducted during or outside
of class with students enrolled in an official course (for credit or
not for credit), as well as activities in fulfillment of class
assignments involving interactions with individuals other than the
members of the class. These assignments are typically initiated and
completed within a single term. Faculty members may design
assignments that engage students in interaction with individuals or
data about individuals to teach research methods or to help students
understand concepts covered by the course. For the most part, they
are not intended to create new knowledge or to lead to scholarly
publication.
Although most student class assignments pose little or no risk to
students or others, some may warrant enhanced attention because of
risks to students or to the individuals outside the class. These
risks may include physical harm or potential psychological, social,
economic, or legal harm, especially when data is collected about
sexual activity, use of alcohol or illegal drugs, or involvement in
illegal activities. Such risks can be exacerbated when the
individuals outside the classroom are minors, pregnant women,
prisoners, or people who are otherwise vulnerable, such as
cognitively impaired persons. When instructors assign students to
collect information about these vulnerable groups, they should take
special care to ensure that students realize the potential for harm
and take all possible steps to eliminate the risks to these
individuals.
NOTE: This policy applies to student class assignments only. Those
independent research projects conducted by students, such as theses,
honors projects, and independent study projects, that collect data
through interactions with living people or access to private
information do fall under the jurisdiction of the IRB. Application
to the IRB for these student research projects must include an
endorsement and acceptance of overall responsibility by a faculty
member.
UNIVERSITY POLICY and INTERPRETATIONS
The University policy on oversight of student classroom activities
turns on the following determinations, rules, and exceptions:
Determination 1: Student class assignments, as a general rule, are
not systematic data collection efforts intended to develop or
contribute to generalizable knowledge and, thus, do not meet the
federal regulatory definition of " research." Therefore, as a rule,
student class assignments do not fall under the jurisdiction of the
IRB and do not require IRB application, approval, or oversight.
Determination 2: An exception to Determination 1 occurs when student
class assignments are intended to collect information systematically
with the intent to develop or contribute to generalizable knowledge.
In this case the assignments are, indeed, "research" and do fall
under the jurisdiction of the IRB. The intent to publish or
otherwise disseminate the results of the activity is one clear
indication that the activity is regulated as research. Instructors
wishing to use such assignments must apply to the appropriate IRB for
review and approval of these assignments before they begin.
See
http://www.irb.research.umich.edu/∞ for information about where
and how to apply.
In reviewing an application for student research conducted in the
context of a course, the IRB may determine that it falls under one of
several defined categories of "exempt" research. A declaration of
exemption means that, so long as there are no major changes in the
research, its conduct does not need to be overseen on a continuing
basis by the IRB. A declaration of exemption does not mean, however,
that students should act any less professionally or be any less
respectful of individuals with whom they interact or about whom they
collect private information.
In reviewing an application for research, the IRB may determine that
it falls under one of several defined categories of "expeditable"
research. Such a determination means that the IRB chair or other
designated person may approve a project on behalf of the entire
committee. If such an application is well formulated and contains
all the information required by the IRB, this process may speed
approval. Expediting reviewers may not disapprove a project.
In reviewing an application for research, the IRB may determine that
it is neither exempt nor expeditable. In such a case, the
application must be reviewed at a convened meeting of the full board.
Class assignments may move from the category of non-research into the
category of regulated research if the faculty member or the students
change their plans to use the data during the data collection or
after the data have been collected. If the faculty member or
students wish to use data collected from class assignments for
research and publication, application to the IRB for permission to
use the data is required.
Determination 3: Even when a class assignment is "non-research" and,
thus, not under the jurisdiction of the IRB, faculty members have an
affirmative obligation to ensure that students understand their
ethical obligations in carrying out their assignments. Instructors
should provide guidance to students collecting information so as to
minimize any unwitting or unintentional harms to other students or to
individuals, especially if students will interact with or collect
private information about vulnerable individuals.
Faculty members have used a number of ways to educate students and
encourage responsible interactions with others. Depending on the
circumstances, faculty may pursue some of the following options:
Reviewing students' plans for classroom or group projects and
suggesting improvements in design and protections for confidentiality.
Suggesting that students take the PEERRS on-line training on human
subject protection before collecting information from others.
Explaining ways in which students should be attentive to the welfare
of individuals in vulnerable situations, such as young children,
prisoners, or the cognitively impaired, or when there is any
possibility of physical harm.
Explaining ways in which students should be attentive to the welfare
in individuals in situations in which students will pose sensitive
questions including topics related to sexual activity, victimization,
use of alcohol or illegal drugs, or involvement in illegal activity.
When written questionnaires are to be used, suggesting that
information be printed on them explaining the use of the data for
coursework and including the name and contact number of the
instructor.
Suggesting, whenever possible, anonymous data collection so that the
data are not linked to individuals.
Suggesting that information identifying individuals be kept
separately from the information collected from those individuals.
Suggesting destruction of non-research data at the end of the course
or within a short time afterward.
Instructing students about the privacy and security vulnerabilities
associated with networked computers.
SUMMARY
Novel and imaginative classroom exercises help students learn and
are, therefore, integral to high quality teaching. All teaching
assignments, however, must respect the rights and welfare of all
individuals involved. The steps an instructor should follow for
assigned class activities involving systematic data collection from
or about individuals are as follows:
1. Consider the nature and intent of the activity. If the course
assignment involves systematic data collection and if any intent of
the activity is to develop or contribute to generalizable knowledge
-- an indication of which is intent to publish or otherwise
disseminate the data -- then the student classroom assignment is
probably research and should be reviewed and approved by the IRB.
Follow the requirements of the IRB.
2. If the intent of the activity is not to develop or contribute to
generalizable knowledge but rather to teach research methodology or
to demonstrate course material and concepts, then the student
classroom assignment is not research and does not require IRB review
or approval.
3. Faculty members should help students understand that they are
obligated to minimize risks to other students or to any other people
with whom they interact to complete their assignments.
4. Ask the IRB for guidance when you are unsure. When does a class
assignment require IRB approval?