Some interviews qualify for an "exempt" review by the IRB, while others require review under an Expedited procedure. Please see the information below to determine if your interview qualifies for Exempt review. Studies that fall under the Exempt category still must be submitted for review by the IRB.
Please note: whenever feasible, researchers should use consent forms when conducting interviews. For an example of an interview consent form, please see Sample Consent Form.
Ethnographic interviews may use an oral rather than written consent process, with protocol akin to those used in journalism:
- interviewees are aware of their rights including the right to retract content and revoke consent for a limited time after completing the interview
- interviewees consent to video or audio recording of the interview
- interviewees state whether they would prefer their identities to remain confidential (quotes are attributed to pseudonyms) or whether they prefer to be explicitly identified
- the interviewer will explain to the interviewee the degree of confidentiality and public use of the recordings and these assurance will be enforced in practice
- if quotes from the interview are to be used by the interviewer, the interviewee will have the right to review the use of the quotes in context
- the interviewer will provide contact information to the interviewee so that he or she can exercise that right
- risk and benefits of participation are provided to the interviewee
- the interviewee is aware at the outset approximately how long the interview may be expected to last
- the interviewee is fully informed that he or she may stop the interview at any time
Risk: Please be explicit and complete when describing the potential risks to your participants. The IRB does not expect research to be risk free, but it has an obligation to evaluate the risks and benefits of each proposal, and it can be difficult for the IRB to assess risks in other cultures.
Degree to which participants are fully informed: The standard written informed consent agreement covers the most important points about which participants must be informed. If you are going to use an oral consent procedure, or if you choose to make up a written form that is more appropriate for your research population, you should still be sure to inform participants of these major points: what they will be asked to do, what risks they might be exposed to, and how you will handle the interview in terms of confidentiality, and most importantly, that participation is fully voluntary and that they can end the interview and withdraw from the study at any time without penalty.)
Documentation of consent: The standard written informed consent agreement provides you with documentation that participants gave informed consent, and it partially protects you and affiliated individuals and institutions from later charges of misconduct. The IRB recommends that written documentation of informed consent be obtained whenever it is appropriate and possible to do so. However, if in your judgment obtaining written consent is inappropriate or risky in itself, please explain why, and explain what you will do to document consent. One alternative is to tape record the interview, or at least the informed consent procedures.
(The guidelines above were adapted from protocols developed by the University of Virginia.)
Most oral histories have recently been excluded from oversight by Institutional Review Boards. However, some interview and oral history research must still be reviewed by the IRB. Please read the information below about exemption category 45 CFR 46.101[b] to determine if your oral history study qualifies for an "exempt" review. Studies that fall under the "exempt" category MUST be submitted for review by the IRB. If your oral history qualifies for an exempt review, please consider the following when submitting your proposal to the IRB:
- Oral History Evaluation Guidelines
- Program/Project Guidelines
- Purposes and Objectives
- Are the purposes clearly set forth? How realistic are they?
- What factors demonstrate a significant need for the project?
- What is the research design? How clear and realistic is it?
- Are the terms, conditions, and objectives of funding clearly made known to judge the potential effect of such funding on the scholarly integrity of the project? Is the allocation of funds adequate to allow the project goals to be accomplished?
- How do institutional relationships affect the purposes and objectives?
When is data collection "Exempt" from IRB review?
Protocol may be Exempt for research activities in which the only involvement of human subjects will be in one or more of the following categories:
- Research conducted in established or commonly accepted educational settings, involving normal educational practices, such as:
- research on regular and special educational instructional strategies, or
- research on the effectiveness of or the comparison among instructional techniques, curricula, or classroom management methods
- Research involving the use of educational tests (cognitive, diagnostic, aptitude, achievement), survey procedures, interview procedures, or observation of public behavior unless:
- Information obtained is recorded in such a manner that human subjects can be identified, directly or through identifiers linked to the subjects; and
- any disclosure of the human subjects' responses outside the research could reasonably place the subjects at risk of criminal or civil liability or be damaging to the subjects' financial standing, employability, or reputation.
- Research involving the use of educational tests (cognitive, diagnostic, aptitude, achievement), survey procedures, interview procedures, or observation of public behavior, if:
- The human subjects are elected or appointed public officials or candidates for public office: or
- federal statue(s) require(s) without exception that the confidentiality of the personally identifiable information will be maintained throughout the research and thereafter.
- Research involving the collection or study of existing data documents, records, pathological specimens, or diagnostic specimens, if these sources are publicly available or if the information is recorded by the investigator in such a manner that subjects cannot be identified, directly or through identifiers linked to the subjects.
- Research and demonstration projects which are conducted by or subject to the approval of department or agency heads, and which are designed to study, evaluate or otherwise examine:
- Public benefit or service programs;
- procedures for obtaining benefits or services under those programs;
- possible changes in or alternatives to those programs or procedures; or
- possible changes in methods or levels of payment for benefits or services under those programs.
- Taste and food quality evaluation and consumer acceptance studies:
- if wholesome foods without additives are consumed or
- if a food is consumed that contains a food ingredient at or below the level and for a use found to be safe, or agricultural chemical or environmental contaminant at or below the level found to be safe, by the Food and Drug Administration or approved by the Environmental Protection Agency or the Food Safety and Inspection Service of the U.S. Department of Agriculture.
The Internet has become a popular medium for data collection. As one example, surveys can be distributed through email networks or posted to public websites. There are many tools available to help you set up surveys for use over the Internet. If you choose to collect data over the Internet, you should use a consent form that contains all of the information required in the printed consent form or the oral consent process. Most interview consent forms conclude by saying, "I have read and understand the above information and voluntarily agree to participate in the research project described above," followed by a line for the participant’s printed name, signature, and the date. For an email or online survey consent form you would replace the signature line with the following text: "By continuing with this survey, I affirm my consent to participant and I acknowledge that I am 18 years of age or older." Depending on the response method and the other characteristics of your own unique proposal, this method of consent may preserve either full anonymity OR confidentiality.
Remember that data collected through email responses is NEVER “anonymous," only “confidential," because participants are identifiable through their email addresses. If you are distributing surveys through email, you should include the following statement in your consent process:
“Although it is unlikely that anyone will try to gain access to your email, you have the right to know that email transmissions are not private and therefore transmission of information through this form cannot be guaranteed to remain confidential.”
As an aside, there are a few methodological drawbacks to using the Internet for data collection. For example, the population of respondents is rarely a random sample from your true population of interest, perhaps violating the accuracy of generalizing your findings to the general population. Furthermore, it is difficult to insure the accuracy of participant characteristics, such as self-reported inclusion in demographic categories. It is also difficult to monitor and exclude multiple responses from the same participant or, in the case of responses using accuracy and reaction time, whether participants are fully focusing on the task or multitasking while they complete the study (see also Pittenger, 2003). For senior project research, it is important that you discuss these and other concerns with your faculty adviser and that you address these methodological constraints in the discussion of your results.
These methodological concerns are NOT a concern for the IRB EXCEPT to the extent that data collection may place your participants at risk. For example, if you were to ask sensitive or potentially incriminating information, email addresses, IP addresses, monitoring of computer use in public spaces, recovery of Internet cache or cookies, date and time of login, information tagged by survey tool websites, and perhaps even individually-identifying information provided by a respondent could all compromise not only the assumed anonymity of respondents, but even confidentiality. In the worst case (unlikely, but not impossible), a participant may face legal charges, or personal, financial, or physical harm due to responding to sensitive questions presented in a survey. The role of the IRB is not to prevent or impair the investigation of sensitive or difficult issues. Bard College maintains a policy of academic freedom and as researchers we appreciate the value of confronting difficult, sensitive, and unpopular topics. It is the role of the researcher to ensure that participants are fully aware of their rights, risks, and responsibilities as they contribute to increased understanding of social and scientific knowledge (Sieber & Stanley, 1988). The role of the IRB in this process is as a national and required body of oversight to affirm that researchers are meeting their responsibilities toward their participants.