The UNH Institutional Review Board (IRB) for the Protection of Human Subjects in Research recently updated its guidance concerning when IRB approval is needed for studies that involve the use of existing/secondary data derived from human subjects.

When studies involve the use of secondary/existing data (data/information that exist(s) at the time the research project begins [e.g., data posted on the Internet, previously collected survey data, school records, medical records]), UNH IRB approval is NOT needed to use such data for research purposes if the secondary/existing data do not contain private information (see the guidance for a definition of "private information"). Some common examples of secondary/existing data that are not considered private information include, but are not limited to:

Some information on the Internet - comments on TripAdvisor; content of public tweets and blogs; information on public Facebook pages; census information; freely-available datasets (whether or not anonymous)

Archives - identifiable information about individuals in a public archive

Datasets - anonymous datasets, whether privately held or publicly available

The IRB, however, cautions researchers that not all information on the Internet is considered publicly available and not all datasets that are characterized as anonymous actually are.  Examples include, but are not limited to: Comments on a non-public chatroom or listserv; restricted-access datasets; or privately held datasets where individuals may be identified, either directly, through a code associated with a name, or through a combination of variables.  As the UNH IRB DOES NOT give post-hoc approval, researchers must be certain before use that the secondary/existing data do not contain private information.  Further, some journals require proof of IRB approval for research projects that the UNH IRB may not consider to involve human subjects (e.g., use of anonymous datasets).  Researchers should check journal requirements before conducting the project and contact Julie Simpson in Research Integrity Services or any IRB member with any questions.

For more information about the IRB, please visit http://unh.edu/research/human-subjects