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Important Regulations and Considerations Regarding Survey Research

Avoid Non-compliance

IRB Non-compliance

Since surveys involve human subjects, you may be required to have your survey reviewed by the IRB if you are doing a survey that is classified as research.  The IRB’s definition of research is any activity that is “a systematic investigation, including research development, testing, and evaluation designed to develop or contribute to generalizable knowledge.”  Even if your survey is not classified as research (e.g., a class project), you still may need to have your survey reviewed by IRB if you are asking sensitive questions or are studying a protected population (see list of protected populations in “Important Considerations”).  To help determine if your study needs to be reviewed by IRB, consult the following flowchart: http://www.irb.wsu.edu/flowchart.asp

Below are scenarios for you to consider when applying for IRB review:

Exemption Determination

If you think your survey research does not involve sensitive questions and/or potential risks to respondents, you can first fill out the Exemption Determination Application to see if your study will qualify as exempt.  If your study is ruled exempt by the IRB, your study’s materials should not include that the IRB reviewed and approved your study.  According to the instructions on the Exemption Determination Application, “If WSU HRPP determines that a study meets the criteria for exemption research, the regulatory requirements for informed consent do not apply.  However, research that is exempt from federal regulations is not exempt from ethical standards as outlined in the Belmont Report.  This means, for example, that if potential subjects will be interviewed in a study that qualifies for exemption, they must be fully informed and free to choose whether or not to participate.”

Non-Exempt

If your survey does not qualify for exemption or is ruled by the IRB as non-exempt, you will need to fill out the Non-Exempt Application.  The IRB will then rule your study as needing expedited or full-board review.

Important Considerations

  • Do not begin survey data collection prior to determination of IRB status (e.g., exemption or approval)
  • If your survey does not meet the IRB’s definition of research, your study may still need to be reviewed by IRB if it asks sensitive questions or is focusing on any of the following protected populations:
    • Children under 14 years outside established educational setting
    • Prisoners
    • Pregnant women
    • Decisionally impaired
    • HIV/AIDS patients
    • Native American Tribes with whom WSU has agreement
    • Crime victims
    • Students or employees under the supervisory or evaluative authority of the researcher
    • Substance abusers
    • Non-English speaking
    • Terminally ill
    • Institutionalized individuals
  • If you do not know if you need IRB approval or exemption contact the IRB coordinator: http://www.irb.wsu.edu/contact.asp

IRB Links

 

Inappropriate Use of State Resources

WSU employee and student use of Qualtrics or REDCap for survey research purposes must adhere to the guidelines for appropriate use of state resources set forth by chapter WAC 292-110-010 in the Washington State Legislature. Because WSU is a public institution, the misappropriation or misuse of University resources for any personal agenda is in direct violation of the above cited policy. Qualtrics and REDCap are University resources provided to WSU employees and students. In line with these guidelines, the use of Qualtrics or REDCap by a WSU organization (employee or student) is to collect information for internal purposes only.  Use must also comply with all other applicable federal and State regulations and therefore users should be mindful of FERPA and HIPAA restrictions on the types of information that can be collected.

  1. Related Links
    1. Washington State Legislature Chapter WAC 292-110-010
    2. Washington State Executive Ethics Board Training
    3. WSU FERPA Training
    4. WSU IRB HIPAA Information

Entering an Unauthorized Click-Through Agreements with Third Party Software Vendors

The Attorney General has determined that click-through agreements constitute an individual negotiated contract with a third-party software vendor on behalf of an umbrella institutional authority.  Stated as such, WSU employees and students cannot use any software that requires a click-through agreement for WSU business or research. When a WSU employee or student clicks on “I agree” they are acting as an agent for WSU to enter in a contract with a third-party software vendor.  This is true even if no monetary exchange has occurred.  WSU employees and students do not have authority to enter in any contractual agreement on behalf of WSU.

NOTED TEMPORARY EXCEPTION:  If you are using a Qualtrics survey, you may click yes, because the terms and conditions are specifically acceptable to WSU through our agreement with them.  WSU is working with Qualtrics to remove this requirement when logging into their system as a WSU representative.

Mishandling of Research Data

  1. Guidelines for the proper handling of research data are discussed relative to two types of data: (1) scholarly work of faculty or students and (2) university data.
  2. The handling of research data collected as part of the scholarly work of faculty or students must adhere to IRB protocol. Such data falls under the definition of research records – the compiled records generated to document the investigation process and resulting data and may include the materials or products generated by research. There is separate WSU policy for managing research records detailed in the Washington State University: Business Policies and Procedures Manual, Research 45.35. This policy relates directly to the appropriate recording of data, length of data retention, data availability, and protecting intellectual property rights.
  3. University Data, or information collected, maintained, and used for the continued operation of Washington State University, must adhere to Executive Policy #8: University Data Policies. University data must not be used to promote or condone discrimination on the basis of race/ethnicity, color, creed, religion, national origin, gender, sexual orientation, age, marital status, the presence of any sensory, mental, or physical disability, or whether a disabled or Vietnam era veteran. University data must not be used to promote or condone any type of harassment, copyright infringement, political activity, personal business interests, or any activity that is unlawful and/or precluded by University policies. Willful misuse of University data, violation of state ethics laws and rules with regard to University data, or other breaches of this policy, can result in termination of access privileges, University disciplinary action, which may include termination of employment, and/or civil and criminal penalties (See links below for Ethics in Public Service, RCW 42.52 and Washington State Executive Ethics Board).
  4. Related Links
    1. Washington State University: Business Policies and Procedures Manual, Research 45.35
    2. Executive Policy #8
    3. Ethics in Public Service, RCW 42.52
    4. Washington State Executive Ethics Board