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Submissions :: Protocol review process :: Expedited/Exempt Review :: Exemption :: Tests, Survey, Interview, Observation

Educational Tests, Survey Procedures, Interview Procedures, Observations of Public Behavior

In most cases, studies that use the above instruments or procedures to collect data are considered minimal risk studies.  The main factor for reducing risk in the studies is that the data are anonymous, thus reducing the most common possibility for harm. Anonymous studies are studies where the participant’s identity cannot be linked to their study data. The federal regulations list the following as situations where exemption cannot be granted:

  1. information obtained is recorded in such a manner that human subjects can be identified, directly or through identifiers linked to the subjects;

    and

  2. 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.


Studies that involve elected or appointed public officials or candidates for public office (using the above instruments and/or procedures) can also be considered for exemption if they do not already qualify under the other designations.

Consent is generally not required for studies that involve surveys, observations, educational tests, and interview procedures.  Documenting consent via a signed consent form may be the only link between the participant and the data which would thus make the data not anonymous.  However, the Board may request that you provide some level of instruction to the participants to inform them about the study.  This information, for example, could be provided as part of the instructions for survey, covering topics such as the purpose of the study, how long it will take to complete, and assuring the participant that the data are anonymous.

Classroom Observations, Educational Tests, Interviews, and Surveys
Observations in education research generally involve observing classrooms while instruction is being given.  The classroom setting is not considered public and will require some level of consent, depending on who is the subject of the observation.  If you are only collecting data on the teacher, then you will need to include this activity in the teacher consent form.  Although you may observe the interaction of the teacher with the students, only the teacher’s identity can be collected (i.e. Mrs. Smith answered student 1’s question…).  If you need to conduct more detailed observations of the students, it may be considered exempt if the observation protocol is justifiable as normal educational practice.  You should describe your observation to the parents in the parental notification you send home.  However, if the Board does not deem it normal educational practice, you will need parental consent and student assent to observe the student.  If the observations are going to be recorded beyond field notes, you will need to consider media use issues, such as a Materials Release Form.  Please see the Media Guide for more information.

As noted below, educational tests qualify for exemption but surveys and interviews do not except in the case where they are considered normal educational practice. In addition to federal regulations regarding research in classrooms, there are additional state and federal regulations as well.  Please see Education: Laws for more information.

Additional instances where a protocol would not be exempted:

  • For studies involving minors, please note that only educational tests qualify for exemption.  Observation of public behavior can be exempt if the researcher does not participate in the activities being observed.  However, all other observations, interviews and surveys of minors require parental consent and minor assent.  The only exception to this rule is if the observations, interviews, and surveys are considered normal educational practice.
  • The instrument(s) is more than minimal risk for a participant.  For example, if an interview or survey involves questions that might upset a participant, the Board may decide that the protocol does not qualify for exemption because it is more than “minimal risk.”
  • Observational research involves sensitive aspects of subjects' behavior, or is in settings where subjects have a reasonable expectation of privacy.
  • Research involves prisoners.

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