The Graduate School, University of Wisconsin-Madison

Human Research Protection Program: Policy

Existing Datasets Policy

Adopted By: All Campus IRB

Adoption Date: November 1, 2001

Purpose:  In many areas of the social sciences, one of the most common methods of research is secondary analysis of publicly available files of data collected from surveys. One of the main sources of such data is the federal government (e.g., Bureau of Labor Statistics). Increasingly, federal agencies require that social science investigators make data collected with assistance of federal funds publicly available. In addition, social science professional organizations and journals are establishing the norm that investigators make data sets used for the production of published scholarly papers accessible in public use data files to encourage scholarly replication of research.

 

In response, UW–Madison’s Institutional Review Boards (IRBs) have developed a policy that research projects involving analysis of secondary data from the following datasets/repositories will NOT require prior IRB approval:

Policy

I.  Analysis of Secondary Datasets

A.  Research projects involving analysis of secondary data from the following datasets/repositories will NOT require prior IRB approval:

 

·         Better Access to Data for Global Interdisciplinary Research (BADGIR)

·         Inter-University Consortium for Political and Social Research (ICPSR)

·         National Center for Health Statistics

·         National Center for Education Statistics

·         National Election Studies

·         Roper Center for Public Opinion Research

·         University of Wisconsin-Madison Data and Information Services Center (DISC)

·         U.S. Bureau of the Census

·         Luxembourg Income Study (LIS)

 

UW-Madison IRBs have determined that data in the above listed datasets has been stripped of identifiers and is publicly available. As a result, research using this data does not rise to the level of “human subjects research,” under the federal Common Rule, 45 CFR Part 46 and UW-Madison policies, and, therefore, does not require IRB review.  See, Defining Human Subjects Research Policy.

 

Note: Research projects that merge more than one dataset in such a way that individuals may be identified are not covered by this policy, and require prior IRB approval.

 

II.   Submitting a Dataset for Pre-approval

A.  Datasets that may qualify for inclusion on UW–Madison's list of approved data sources include:

 

1.  Public use datasets posted on the Internet that include a responsible use statement or other confidentiality agreement for authors to protect human subjects (for an example, see the ICPSR's responsible use statement)

 

2.  Survey data distributed by UW-Madison principal investigators who can certify that:

 

a.  the data collection procedures were approved by an IRB that satisfies the Common Rule criteria for an IRB, and

 

b.  the dataset and documentation as distributed do not contain information that could be used to identify individual research participants.
B.  Investigators must submit the following information on potentially eligible datasets to the IRB office prior to conducting research:

 

1.  Name of dataset

 

2.  URL of the dataset or other information on how to obtain the dataset

 

3.  Abstract (one page maximum) describing the content of the dataset and its potential use