Social Science, Behavioral, and Educational Research IRB (HSC)

The Department of Psychology has a committee that reviews research studies involving the psychology pool participants BEFORE they are submitted to the IRB. The guidelines on what and how to submit to this Committee can be found at “Using Intro Psych participant pool. You will also find information on how to structure your study and language you must include in your consent. The certificate that you are given at the end of the checklist must be submitted to the IRB with your protocol documents. This certificate should be uploaded into the Supporting Documents tab of the protocol in the IRES IRB system. The submission will be returned to you if this certificate is not submitted.

In order to enroll medical students in your research study you must have the protocol reviewed and approved by The Committee to Review Student Participation BEFORE it is sent to the IRB. See the Policy for more information. The approval letter you receive should be uploaded into the Supporting Documents tab of the protocol in the IRES IRB system.  The submission will be returned to you if this approval letter is not submitted.

If you have applied for or received fellowship funding, please see the Yale Fellowships and Funding page  for instructions and guidance on submitting to the IRB.

When conducting international research please fill out the International Research Checklist and submit this to the IRB with your application.

Sensitivity to local culture:

• Keep in mind that the risks to subjects are likely to differ from country to country.

Consent in local language:

• Do you speak the local language or are you using a translator?
• You should provide subjects local contact information—both yours and either the local ethics review board in country, your local in country advisor or that of the local agency or NGO you are affiliated with.

Hiring local people to help with the conduct of the study:

• Depending on who they are, the role they will play in your research, and whether they have their own IRB, local personnel may need to be added as Unaffiliated Investigators. You can consult with the IRB office to help you make this determination.
• They need to be trained in human subjects protection
• They may need to sign a pledge of confidentiality

Local IRB or Ethics Board review in the country you intend to conduct the research

Keep in mind local IRB/ethics board approval

• Is generally not quick
• May have requirements unique to the host country
• May charge for services
• May require approval at a level beyond the local IRB (e.g. a national ethics board)
• If There Is No Local IRB, you can find the following:
  • A local independent ethics committee
  • A local ethics board
• If these do not exist, seek out an agency that can act in a similar capacity and provide you with a Letter of Support for your research:
  • a town committee
  • a tribal council
  • a hospital board
  • an NGO or other agency

When collecting education records from students (K-12 and higher education) The Family Educational Rights and Privacy Act (FERPA) and the Protection of Pupils Rights Amendment (PPRA) are two laws that must be taken into consideration. FERPA (20 U.S.C. § 1232g; 34 CFR Part 99) is a Federal law that protects the privacy of student education records. The law applies to all schools that receive funds under an applicable program of the U.S. Department of Education. It is the investigator’s responsibility to be aware of when these laws would affect their research and to be aware of his/her obligations with the school.

FERPA

Generally, schools must have written permission from the parent or eligible student in order to release any information from a student’s education record. However, FERPA allows schools to disclose those records, without consent, to the following parties or under the following conditions (34 CFR § 99.31):

• School officials with legitimate educational interest;
• Other schools to which a student is transferring;
• Specified officials for audit or evaluation purposes;
• Appropriate parties in connection with financial aid to a student;
• Organizations conducting certain studies for or on behalf of the school;
• Accrediting organizations;
• To comply with a judicial order or lawfully issued subpoena;
• Appropriate officials in cases of health and safety emergencies; and
• State and local authorities, within a juvenile justice system, pursuant to specific State law.

Schools may disclose, without consent, “directory” information such as a student’s name, address, telephone number, date and place of birth, honors and awards, and dates of attendance. However, schools must tell parents and eligible students about directory information and allow parents and eligible students a reasonable amount of time to request that the school not disclose directory information about them. Schools must notify parents and eligible students annually of their rights under FERPA. The actual means of notification (special letter, inclusion in a PTA bulletin, student handbook, or newspaper article) is left to the discretion of each school.

PPRA

The PPRA applies to the programs and activities of a State educational agency (SEA), local educational agency (LEA), or other recipient of funds under any program funded by the U.S. Department of Education.  It governs the administration to students of a survey, analysis, or evaluation that concerns one or more of the following eight protected areas:

• political affiliations or beliefs of the student or the student’s parent;
• mental or psychological problems of the student or the student’s family;
• sex behavior or attitudes;
• illegal, anti-social, self-incriminating, or demeaning behavior;
• critical appraisals of other individuals with whom respondents have close family relationships;
• legally recognized privileged or analogous relationships, such as those of lawyers, physicians, and ministers;
• religious practices, affiliations, or beliefs of the student or student’s parent; or,
• income (other than that required by law to determine eligibility for participation in a program or for receiving financial assistance under such program).