Institutional Review Boards (IRBs)
IRB Review of Public-Use Data
IRBs take different approaches to secondary analysis of public-use datasets such as those distributed on ICPSR's website. Some require IRB review of proposals to analyze these data. Others exempt projects involving secondary analysis of existing datasets from preapproved sources, such as ICPSR. Others are establishing their own policies to address these issues.
IRB Review of Restricted-Use Data
College and university Institutional Review Boards (IRBs) review research proposals in order to safeguard human subjects who participate in biomedical or behavioral research. Confidentiality and disclosure risk limitation are major concerns of IRBs. Typically, the IRB of a researcher's institution must review proposals to analyze ICPSR restricted data and ICPSR enclave data. The IRB approval is submitted with the researcher's application to access the data. Some universities exempt secondary analysis projects from review. They take the position that secondary data analysis does not involve research on human subjects. In these cases, a researcher's application to access restricted data must include a declaration that the project is exempt from the institution's IRB review.
ICPSR's Confidentiality Policies
ICPSR's own confidentiality policies are often of interest to IRBs that are making policies regarding analysis of data. These are the most relevant statements:
Confidentiality Policy Statement
ICPSR considers the protection of confidentiality in archived data to be of paramount importance in its service to the social science research community. Since its inception in 1962, ICPSR has routinely subjected all data deposited in the archive to rigorous examination with respect to disclosure risk. All data collections acquired by ICPSR undergo confidentiality review to determine whether the data contain any information that could be used to identify respondents. Should such information be discovered, general practice is to alter the sensitive data after consultation with the principal investigator to create public use files that limit the risk of disclosure.
Agreement about Confidentiality from the ICPSR By-laws
Member institutions agree that data and other materials provided by ICPSR are to be used solely for statistical analysis and reporting of aggregated information, and not for investigation of specific individuals or organizations, except when identification is authorized in writing by ICPSR. Each member institution gives assurance that such uses of statistical data will conform to widely-accepted standards of practice and legal restrictions that are intended to protect the confidentiality of research subjects. (1.2.C)
Responsible Use Statement
Users of ICPSR data agree to a responsible use statement before downloading data from the website. It reads, in part:
Any intentional identification or disclosure of a person or establishment violates the assurances of confidentiality given to the providers of the information. Therefore, users of data obtained from the ICPSR agree:
To use these datasets solely for statistical analysis and reporting of aggregated information, and not for investigation of specific individuals or organizations, except when identification is authorized in writing by ICPSR
To make no use of the identity of any person or establishment discovered inadvertently, and to advise ICPSR of any such discovery
To comply with the request that downloaded material not be redistributed or sold to other individuals, institutions, or organizations without the written agreement of ICPSR