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248 lines
12 KiB
Markdown
248 lines
12 KiB
Markdown
# IRB Decision Tree — Human Subjects Research Ethics Review Guide
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## Purpose
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IRB (Institutional Review Board) ethics review decision tree and Taiwan process guide. Used by the ethics_review_agent to determine whether research involves human subjects, and by the research_architect_agent to plan IRB review during methodology design.
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---
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## 1. Human Subjects Research Determination Decision Tree
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```
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Does your research collect, use, or analyze data from humans?
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│
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├── No → Does not involve human subjects, no IRB review needed
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│ (e.g., pure theoretical research, literature review, secondary analysis of public statistics)
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│
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└── Yes → Is the data personally identifiable?
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│
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├── No → Is the data publicly available public data?
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│ │
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│ ├── Yes → Typically exempt from review
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│ │ But must still submit an exempt review application to IRB for confirmation
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│ │
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│ └── No → Proceed to "Review Level Determination" below
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│
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└── Yes → Does the research involve direct interaction with subjects?
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│
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├── No → Only uses existing data/specimens
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│ │
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│ ├── Data already de-identified → May apply for exempt review
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│ └── Data contains identifiable information → Expedited or full board review
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│
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└── Yes → Proceed to "Review Level Determination" below
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```
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---
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## 2. Three-Level Review System
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### 2.1 Exempt Review
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**Applicable Conditions** (any one of the following):
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- [ ] Uses publicly available, de-identified datasets
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- [ ] Research on educational practices in normal educational settings
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- [ ] Involves only anonymous surveys (no sensitive topics)
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- [ ] Observation of public behavior (no identifiable information recorded)
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- [ ] Uses government public statistical data
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**Note**: Exempt review does not mean exempt from application — you must still submit to IRB to confirm exempt status.
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### 2.2 Expedited Review
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**Applicable Conditions** (all must be met):
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- [ ] Research risk is no greater than risks ordinarily encountered in daily life (minimal risk)
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- [ ] Does not involve vulnerable populations
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- [ ] Research methods are on the expedited review category list
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**Common Categories**:
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- Surveys (containing sensitive but not high-risk topics)
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- Interviews (general topics)
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- Teaching intervention research (non-invasive)
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- Audio/video recording (with consent)
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- Secondary analysis of previously collected clinical data
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### 2.3 Full Board Review
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**Applicable Conditions** (any one of the following):
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- [ ] Greater than minimal risk
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- [ ] Involves vulnerable populations (children, prisoners, pregnant women, individuals with cognitive impairments)
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- [ ] Involves sensitive topics (sexual behavior, illegal behavior, mental health)
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- [ ] Uses deception
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- [ ] May cause psychological or social harm
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---
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## 3. Taiwan IRB Process
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### 3.1 Governing Authorities
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| Authority | Jurisdiction | Legal Basis |
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|-----------|-------------|-------------|
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| **National Science and Technology Council (formerly MOST)** | NSTC-funded projects involving human research | "NSTC Guidelines for Research Grant Applications" |
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| **Ministry of Health and Welfare** | Human research, clinical trials, human biobanks | "Human Subjects Research Act" (2011) |
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| **Ministry of Education** | Research ethics in educational settings | Institutional regulations |
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### 3.2 Regulatory Framework
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| Regulation | Scope | Key Requirements |
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|-----------|-------|------------------|
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| **Human Subjects Research Act** | Research involving human subjects (surveys, interviews, observations, interventions) | Prior review, informed consent, personal data protection |
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| **Personal Data Protection Act** | Collection, processing, and use of personal data | Notification obligation, purpose limitation, security maintenance |
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| **Regulations Governing Human Trials** | Drug/medical device clinical trials | GCP compliance, subject insurance |
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### 3.3 Application Process
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```
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1. Write research proposal
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↓
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2. Determine whether human subjects are involved
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↓ (Involved)
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3. Confirm review level (Exempt / Expedited / Full Board)
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↓
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4. Submit application to institutional IRB
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- Research proposal
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- Informed consent form
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- Questionnaire/interview guide
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- Researcher qualification documentation (CITI or equivalent training)
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↓
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5. IRB review (timeline: Expedited 2-4 weeks, Full Board 4-8 weeks)
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↓
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6. Research may only begin after receiving approval letter
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↓
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7. Periodic progress reports (typically annual)
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↓
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8. Final report
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```
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### 3.4 Online Research Ethics Review Platforms
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| Platform | Description | URL |
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|----------|-------------|-----|
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| **AREC** (Academic Research Ethics Committee) | Multi-institutional joint ethics review committee | Institutional IRB websites |
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| **Institutional IRB systems** | Online application systems within universities | Institutional R&D office websites |
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| **CITI Program** | Online research ethics training course | citiprogram.org |
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| **Taiwan Research Ethics Education Resource Center** | Research ethics education materials | Institutional teaching development centers |
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---
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## 4. Higher Education Research Quick Reference Table
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| Research Scenario | Involves Human Subjects | Recommended Review Level | Notes |
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|-------------------|------------------------|--------------------------|-------|
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| MOE public statistical data analysis | No | Exempt | Already publicly available de-identified data |
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| Institutional research (IR) data analysis | Depends | Exempt/Expedited | Depends on whether data is de-identified |
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| Student learning outcome survey | Yes | Expedited | Anonymous surveys typically qualify for expedited review |
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| Teacher interviews (general teaching experience) | Yes | Expedited | Non-sensitive topics |
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| Teaching experiment (A/B teaching method comparison) | Yes | Expedited/Full Board | Depends on whether it affects students' grades/rights |
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| Student mental health survey | Yes | Full Board | Sensitive topic |
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| Vulnerable student population study | Yes | Full Board | Vulnerable population protection |
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| Student learning portfolio analysis | Depends | Expedited | Contains identifiable information requiring expedited review |
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| Classroom observation (no personal data recorded) | Yes | Exempt/Expedited | Public setting observation |
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| Graduate career tracking survey | Yes | Expedited | Contains personal data requiring expedited review |
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| HEEACT accreditation data analysis | Depends | Exempt/Expedited | Publicly available portions exempt from review |
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| University faculty salary/labor conditions survey | Yes | Expedited/Full Board | May involve institutional power dynamics |
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---
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## 5. Informed Consent Form Elements
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### 5.1 Required Items
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- [ ] Research title
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- [ ] Research institution and principal investigator name
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- [ ] Research purpose
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- [ ] Research procedures description (what subjects need to do, how long it takes)
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- [ ] Potential risks and discomfort
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- [ ] Potential benefits
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- [ ] Confidentiality measures (how data is stored, who has access, retention period)
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- [ ] Voluntary nature of participation (may withdraw at any time, no penalties)
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- [ ] Researcher contact information
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- [ ] IRB contact information (complaint channel)
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- [ ] Subject signature and date field
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### 5.2 Special Situations
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| Situation | Additional Requirements |
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|-----------|------------------------|
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| **Online survey** | Electronic consent (clicking "I agree" constitutes consent); must state that IP addresses will not be recorded |
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| **Audio/video recording** | Separate checkbox item: consent to audio/video recording |
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| **Minors** | Legal guardian consent + subject assent |
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| **Cross-national research** | Comply with local IRB requirements + Taiwan IRB requirements |
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| **Indigenous research** | Community consent (tribal consent) + individual informed consent |
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### 5.3 Informed Consent Form Template Structure
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```
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Research Participation Consent Form
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1. Research Project Title: [ ]
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2. Principal Investigator: [ ] / Institution: [ ]
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3. Research Purpose: [ ]
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4. Research Methods and Procedures:
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You will be invited to [specific description of what the subject will do],
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estimated to take [ ] minutes.
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5. Potential Risks or Discomfort: [ ]
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6. Potential Benefits: [ ]
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7. Confidentiality Measures:
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Your data will be processed using codes; research results will only be
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presented in aggregate form, and your personal identity will not be
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disclosed. Data will be destroyed after [X] years.
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8. Voluntary Nature of Participation:
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You are free to decide whether to participate in this study and may
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withdraw at any time without any adverse consequences.
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9. Contact Information:
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Principal Investigator: [Name] [Phone] [Email]
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IRB Contact: [Institution Name] [Phone] [Email]
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□ I have read and understood the above explanation and agree to participate
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in this research.
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Subject Signature: __________ Date: __________
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Researcher Signature: __________ Date: __________
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```
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---
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## 6. Data De-identification and Privacy Protection
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### 6.1 De-identification Strategies
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| Strategy | Description | Applicable Scenario |
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|----------|-------------|---------------------|
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| **Anonymization** | Complete removal of all identifiable information, irreversible | Final data publication |
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| **Pseudonymization** | Replace with codes, retain a linkage table | Need to track during research process |
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| **Data generalization** | Convert precise values to ranges (e.g., age → age group) | Statistical analysis |
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| **Data masking** | Hide partial information (e.g., partially masked email) | Data display |
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| **k-anonymity** | Ensure each record is indistinguishable from at least k-1 other records | Dataset release |
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### 6.2 Common Privacy Risks in Higher Education Research
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- **Small sample identification**: Small departments may allow re-identification through descriptive statistics
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- **Cross-referencing**: Combining multiple de-identified datasets may enable re-identification
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- **Narrative identification**: Qualitative research quotations may reveal interviewee identity
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- **Institutional identification**: Overly specific institutional characteristics may allow institution identification
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### 6.3 Recommended Practices
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- [ ] Remove direct identifiers (names, student IDs, national ID numbers)
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- [ ] Assess indirect identifier risks (department + year + gender combinations may identify individuals)
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- [ ] Check qualitative quotations: remove identifiable details
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- [ ] Handle institutional names: decide whether to anonymize based on research needs
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- [ ] Encrypt data storage with access controls
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- [ ] Establish data retention and destruction timeline
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---
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## Quick Reference: Researcher Self-Check
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Before starting research, answer the following questions:
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1. [ ] Does my research collect, use, or analyze human-related data?
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2. [ ] If yes, is the data completely de-identified and publicly available?
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3. [ ] If not, which level of IRB review do I need to apply for?
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4. [ ] Have I completed research ethics training (CITI or equivalent)?
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5. [ ] Does my informed consent form include all required elements?
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6. [ ] Do I have an appropriate data protection plan?
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7. [ ] If vulnerable populations are involved, are there additional protective measures?
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8. [ ] Has the IRB review timeline been incorporated into the research project timeline?
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