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Using the Internet to Collect Data

When you use the internet to collect data, you need to consider how the data storage and collection will protect participant confidentiality. You need to devise a way to document consent, and you need to explore the possibility of minors inadvertently participating in the study.

Confidentiality and Anonymity
Most internet research involves collecting data through surveys.  In paper form, a survey could be easily distributed and collected in such a way that no identifiers are attached to the survey, thus rendering it anonymous. The internet, however, was developed to collect information about the user, from the IP address to more sophisticated ways of tracing preferences and choices, so it is important that you use legitimate services that will collect data in a secure manner.  An email is generally not anonymous unless it is run through special software.  You need to explain to the Board how you will collect your data so that no identifiers are collected; if this condition is met the protocol will most likely qualify for exemption.  If you are collecting identifiers, you need to justify why this is necessary and you need to develop a procedure for documenting consent if you are gathering sensitive information.

Documenting Consent
If the protocol is exempt, the Board usually requires that you provide some information at the beginning of the survey informing the participant of the purposed of the study, what they will do, how long it will take, and any issues regarding confidentiality.  You should also include information on how to terminate the survey and withdraw, if possible. 

If you are required to document consent, your participants need to submit a signed copy of a consent form unless you are able to document electronic signatures. The Board is able to grant a waiver of documentation of consent if the collection of signatures is a risk to the participant or if the research presents no more than minimal risk to the participants and involves no procedures for which written consent is normally required outside of the research context. For example, if a study was not exempt, but qualified for expedited review, the Board could grant a waiver of documentation of consent, thus allowing the researcher to assume consent based on the participant’s willingness to complete the survey.  In such cases, providing information about the survey as explained in the paragraph above would be appropriate.

Minor Participation
In most cases, minors are not allowed to participate in research without parental permission.  Surveys involving minors are not exempt under Subpart D except when the survey qualifies as normal educational practice. Thus in order to include minors in an online study, you need to describe a mechanism for obtaining consent from parents and assent from the minor. If your study does not include minors, you need to consider the possibility that a minor might access your online survey and participate without parental permission.  For studies that involve sensitive subjects, you should devise ways to deter minors from participating.

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