IRBs and the Shelf Life of Ethnographic Data

An anthropology department was faced by its IRB’s policy of having investigators either destroy data with identifications, including photographs, or destroy or lock up the identifications, or face not being in compliance in any future publications. This anthropology department answered its IRB with a request that ethnographic data in the context of anthropological research be exempt from this rule under certain conditions (longevity of the research project, length of commitment of the researcher to the community, provision for identifications to be destroyed upon the death of the researcher). The department sought what other departments have done in responding to similar challenges, leading to a discussion on the AAA’s department listserv.

Several suggestions about how to respond to such hurdles posed by such “over-enforcing” IRBs were offered by discussion participants:

1) Volunteer to sit on your institution’s IRB to provide anthropological insight and expertise.

2) Keep ID numbers and personal information separate. The ID numbers are used in analysis, a key linking the ID numbers to individuals is kept separate and under key, and personal information is kept separate from both and also under key. This makes it virtually impossible for anyone not directly involved in the project to link IDs with individuals (although someone could potentially do so in the future if the need arose).

3) Invite anthropologists with “expertise” in IRB policy at the federal level to visit your campus to address IRBs issues with relevant people.

4) Continue the discussion of these issues in Anthropology News as sources of information for members.

5) Provide roundtable discussion on IRB matters during AAA annual meetings and section meetings so members can effectively address these issues at their home insititutions.

Several things to keep in mind when thinking about this case were posed by discussants:

1) Context in which the research is being done is key in determining how to “protect” ethnographic data, and in thinking about issues of “cultural patrimony” and the methods of data gathering and analysis.

2) IRBs need to be educated about ethnography since many operate out of a biomedical model.

3) IRBs need to be educated about federal standards (the Common Rule), how to interpret the Common Rule in light of different types of research, and not to exceed the federal rules in fear of being punished for not complying to them.

Resources for departments in facing similar dilemmas were also offered:

1) AAA Statement on Ethnography and Institutional Review Boards

2) AAA Code of Ethics

3) American Association of University Professors Report, “Protecting Human Beings: Institutional Review Boards and Social Science Research”

4) National Science Foundation policy guidance; contact NSF's Human Subjects Research Officer Stuart Plattner, email: splattne@nsf.gov

5) Free Consultation on Human Subjects Protections: The Office for Human Research Protections (OHRP) has a new toll-free telephone number available to all within the research community to consult with OHRP on matters of human subject protections. The toll-free number is 866/447-4777 [HHS-HRPP].

6) The Wenner-Gren sponsored Council for the Preservation of Anthropological Records (CoPAR): Sydel Silverman and Nancy J. Parezo (eds), Preserving the Anthropological Record. New York: Wenner-Gren Foundation for Anthropological Research, Inc., 1995. In addition, please go to their webpage for a series of CoPar's on-line publications, including one about the ethical use of anthropological records.