Do I need ethics approval for secondary research?
Secondary Research refers to the research or analysis of an existing dataset (i.e. primary data) that was previously collected for some other “primary activity".
Such primary data could comprise of previously collected data (for a separate study), or data transferred from a collaborator (for a separate study), or datasets already published in public data repositories (e.g. DR-NTU or journal repositories), or data publicly available on the internet, or student/ medical records, etc.
Secondary research is usually non-interventional in nature, as new data is NOT collected from participants. Despite this, secondary research involving the use of identifiable data falls under the scope of Singapore's PDPA and HBRA, hence IRB approval is required. (Refer to IRB's purview here.)
IRB Procedure:
- If the data received is fully anonymised and not re-identifiable, then the study may qualify for Review Not Required (RNR) category, as this is not considered Human Subjects Research.
- If the data is potentially re-identifiable, then the study may qualify for Exempt Cat. 4 review and approval.
- If the data is being used in an identifiable format, then they study will under Expedited review.
Note:
Researchers should note that journals/publishers* often require ethics approvals for secondary research. Hence, researchers are advised to obtain ethics approvals prior to your secondary research as retrospective reviews and approvals will not be provided. (Refer to our guidance on journals/publishers requiring ethics approvals here.)
* NTU is a member of the international Committee on Publication Ethics (COPE), and adheres to international best practices on publication and research ethics. Please refer to COPE's case example 1, example 2. and example 3.