If an activity falls under the category of human subjects research, it is regulated by the federal government and Teachers College (TC) Institutional Review Board (IRB). TC IRB has provided a guide to help researchers determine if their activities can be considered human subjects research.
Internet research is a common practice of using Internet information, especially free information on the World Wide Web or Internet-based resources (e.g., discussion forums, social media), in research. This guide will cover considerations pertaining to participant protections when conducting Internet research, including:
The following information is from an NIH videocast. (Odwanzy, L. (2014, May 8). Conducting Internet Research: Challenges and Strategies for IRBs [Video]. VideoCast NIH. https://videocast.nih.gov/summary.asp?Live=13932&bhcp=1)
Federal regulations define a category of human subjects research that is exempt from IRB review as:
“Research that only includes interactions involving educational tests (cognitive, diagnostic, aptitude, achievement), survey procedures, interview procedures, or observation of public behavior (including visual or auditory recording).”
With regards to online information, if the data is publicly available (such as Census data or labor statistics), it is usually not considered human subjects research. However, if the data includes identifiable information—meaning the data can be linked back to a specific individual—then it may need to undergo IRB review. Additionally, de-identified data pulled from a private source, such as data provided by a company, may also be considered human subjects research.
Public behavior is any behavior that a subject would or could perform in public without special devices or interventions. Public behavior on the Internet, however, is more difficult to pinpoint. Federal regulations indicate that an environment may be private if a reasonable user would consider their interactions in that environment to be private. To help identify public behavior on the Internet, consider:
TC IRB will determine whether an Internet environment is private or public based on the IRB protocol submission.
Identifiable data is information or records about a research participant that allows others to identify that person. Names, social security numbers, and bank account numbers are considered personal identifiers and are protected under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). TC IRB has a blog posted on Understanding Identifiable Data that further explains the different types of identifiers. Data that includes personal identifiers does not fall under the Exempt category.
Other types of participant information may include indirect identifiers, such as birthdate, age, ethnicity, gender, etc. Taken alone, these pieces of information are not enough to identify any single participant. However, researchers have shown that certain combinations of these identifiers may identify participants. For example, Sweeny (2000) demonstrated that 87% of the United States population could be uniquely identified based solely on their ZIP code, gender, and date of birth.
It is important to remember that while data may be publicly available, it may still contain identifiable information. In these cases, the IRB will decide the risk to participants on a case-by-case basis. With Internet information, consider these to be possible identifiers:
In cases where sensitive Internet data must be used for research purposes, researchers should take precautions to ensure the safety and privacy of participants. The nature of online research increases risk to participants in some areas. Researchers should develop a plan to minimize risk in the following areas:
The Secretary’s Advisory Committee on Human Research Protections (SACHRP) has provided examples of common Internet research practices. These include elements of research conducted over the Internet. Below are possible examples of Internet research where human subjects may be involved:
Increased Internet use for research requires researchers and IRBs to become familiar with Internet research-related topics and concerns. Research submitted to the IRB will be reviewed on a case-by-case basis. The Institutional Review Board at Teachers College will make the final determination of whether a study requires review. Researchers should email IRB@tc.edu if they have any questions or concerns about their study design and whether it should be IRB reviewed.