Misc. Issues including FERPA and A/V Guidance (Section 6)

6.1 What is FERPA and does it apply to research?

  • Contact the Registrar's Office for more information about use of KSU records.
  • Important; students records should not be retained and used for purposes other than what they've been approved, this includes use of student email addresses. 
  • The Federal Educational Rights and Privacy Act (FERPA) is a federal law that protects the privacy of student records, both financial and academic. FERPA laws apply to research projects. For more information and to learn if FERPA rules apply to your research, click here.
  • If you will be using FERPA protected information as part of your study, we recommend working with the FERPA officers in advance of submitting your IRB application. 

6.2 Should I submit an amendment or a new application?

  • The general rule of thumb is that if you change any two of the three Ps (purpose, population, procedure) with one amendment request you need to submit a new application. If you change any two of the three over multiple amendment requests or if you are unsure if you need to submit a new application or an amendment, please contact the Office of Research Compliance.

6.3 Amendments

  • All amendments to currently approved human subjects research studies must be approved by the IRB prior to implementation except those that are made to avoid apparent immediate harms.
  • If a change needs to be made to eliminate apparent immediate harms to a subject or group of subjects the researcher must make the necessary change(s) to protect the safety, wellbeing, and welfare of the subjects and may do so without prior IRB review. Any such changes must be reported to the IRB as soon as is reasonably possible.
  • The criteria for reviewing amendments are the same as initial review criteria.
  • Major amendments to full board projects must be reviewed by the full board. Minor amendments to full board projects can typically be reviewed through an expedited process.
  • Changes that increase the initial level of approval will need to be re-reviewed through the appropriate expedited or full board process. The IRB will need to understand the status of currently enrolled subjects and whether they will be contacted to complete the new or revised procedure(s). Example, if blood draws are added to a study that was exempted under the benign behavioral interventions category, that study can no longer be considered exempt and will need to be reviewed through an expedited or full board process; blood draws are not considered benign behavioral interventions.
  • When amending a project it is important to consider how the change affects other parts of the project – it is not uncommon for the IRB to request revised recruitment and consent materials that were not included with the initial submission.

6.4 Does Title IX apply to research?

  • Yes, you must follow KSU Title IX policy.

6.5 Whom do I contact with questions? 

  • The Office of Research Compliance is here to help and you can contact us at researchcompliance@kent.edu. You can also contact any IRB member.

6.6 What do I need to know about Certificates of Confidentiality?

6.7 Issues related to audio and/or video recording (including photography)

  • Recording should only be conducted when necessary to conduct the research.
  • Recordings are considered identifiable until they are de-identified. Even if a recording does not capture an individual's face it may record other identifiers such as tattoos, birthmarks or vocal characteristics.
  • Researchers are responsible for knowing the recording laws for the jurisdiction where they are conducting the research. 
  • Personal cellphones should not be used to record.
  • Consent must be obtained from participants for future use of the recordings.
  • When recording in group settings you should have a plan for excluding those who wish to not be recorded. It is acceptable in most circumstances to exclude subjects who do not want to be recorded - prospective subjects should be advised of this. 
  • The consent process must explain the use of the recordings, what will be captured, storage, and retention/destruction.
  • If recording is optional, the consent form should include an additional line for express permission (see consent template).