The Committee for the Protection of Human Subjects is charged by Mills College to oversee the health and welfare of human participants involved in research or projects that involve systematic contact (see below). The committee follows the guidelines established by federal and state regulations. It is important to understand also that, although the federal guidelines are primarily established to protect the human participant, the process of review and informed consent also serves to protect the researcher and the College.
Everyone working with human participants should ask themselves this question. Here are some guidelines to help you decide if your work needs human subjects review.
Research is defined as systematic investigation, interaction (communication and interpersonal contact), intervention (data gathering and manipulations of the individual’s environment), examination (testing, evaluation), or the gathering of identifiable personal information (information about behavior or opinions in the absence of formal observation or data recording that potentially identifies a particular individual) that is designed to contribute to generalized knowledge. Demonstration, service projects, and creative or artistic projects that involve systematic contact with human participants with the goal of contributing to generalizable knowledge are considered “research.” These projects often include the use of video or interview material. All “research” projects that are being funded by external or internal sources (e.g., Barrett undergraduate research grant) must be submitted for review.
As a rule of thumb, research projects that require review typically result in some form of systematic or formal presentation, including senior thesis or senior project, conference presentation (including the Mills Undergraduate Research Conference), publication, community video presentation, etc. Interaction or observation of human participants that is supervised within the context of a single class assignment is under faculty supervision and not subject to human subjects review. Faculty who utilize this form of “research” as a consistent pedagogical technique in their courses may wish to submit for review a generic proposal that covers these instructional “research” activities.
Individual service learning projects as typically organized at Mills are not subject to review. These projects usually involve, in addition to the actual hours of service, (1) student participation in a Mills Cares Seminar, (2) student participation in an already approved faculty project, or (3) written service learning response papers. If service learning is being used to, however, to contribute to generalized knowledge through a semester long group project that is systematic and draws together the work all of the students in a class, the committee recommends that the faculty member in charge of this project submit either a proposal specific to that project or a generic proposal as described above.
It can be difficult to determine if a demonstration, service project, or creative/artistic project is subject to review. Here are two key elements to consider in determining if your project needs to be reviewed. One element is how you select the human participants. If you are selecting a group of participants by approaching them (by letter, announcement, internet, or in person) and asking them if they wish to participate in your work (random selection, or based on a set of participation requirements, e.g., females between 18 and 24 years of age), then you may indeed be doing “research.” The other element to consider is whether or not the goal of your project is to contribute to generalized knowledge. If your goal is to contribute to the understanding of a phenomenon (e.g., why do individuals wear clothing with sports logos) then you are contributing to generalized knowledge. Creative projects traditionally in the arts and journalism are not considered research. Note though that video arts projects are often artistic research projects and may be subject to review.
As of October 2003, oral history projects are exempt from human subjects review. Oral history is defined as interviews that are designed to explain a particular past. The individuals who are interviewed are selected because of their unique relationship to and perspective on the topic under pursuit.
Above all, if you are uncertain about whether or not your project needs to be reviewed, get more information. Students should contact their advisors. The committee chair can also answer questions.
No. Review is the first step in “research” projects recruiting and interaction with human participants may not begin until the project has been approved. The researcher is notified in writing when the approval process has been completed. Be sure to keep this letter on file, as you may be asked to provide evidence of approval (e.g., when applying for funding, when approaching other institutions for permission to recruit participants).
Informed consent is key to the process of protecting human participants. Informed consent is typically documented through the use of a written signed consent form that describes the nature of the project and what the participant should expect to experience. It also establishes in writing that the participant has the discretion to withdraw from the project at any time without ill consequence. The consent form should be written in a language that is understood by the participant. If reading is a problem, the consent form should be read to the participant. The participant should be allowed to ask questions about the project prior to signing the consent form. The consent form must be signed by both the researcher and the participant, or his/her legal representative (e.g., a child’s parent or guardian). A copy of the signed consent form must be provided to person signing the form.
Some projects do not require written signed consent. These projects include interaction with adult participants where failure to provide consent is clearly interpreted from the individual’s nonparticipation (e.g., failure to return an anonymous survey; internet surveys), where the researcher is a “participant observer” (a technique that is popular, for example, in anthropological studies), or some naturalistic observation projects that involve no intervention or interaction with human participants.
Let the committee know the status of your project. There are occasions when a project has already been approved but you wish to change or add to the data collection procedures or the manner by which you contact, interview, or interact with your participants. Simple additions or changes do not required full submission of another research protocol. Rather, submit in writing to the committee chair information about the revisions you propose. These revisions will be reviewed; once approved, they are added to your original proposal. As with the original proposal, (1) documents submitted for project changes are not reviewed during academic breaks and (2) revisions cannot be implemented until you have received written approval of the changes.
Some individuals find that their original research or project ideas do not work out and that they must develop new project. New projects are treated in the same way as first time submissions. This means that a new proposal must be submitted to the committee for review. Approval of a different project under your name or the names of others in your group does not constitute approval for new projects that have different goals and methods of interacting with human participants.