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This is for a research paper, and the survey was sent to thousands of people through publically available email information.

Because the response rate is low, and we don't ask for any self-identity information, it is a truly anonymous survey.

We already finished the process, but someone shows concern about whether our anonymous online survey needs IRB approval.

Any ideas and links to valid sources are appreciated.

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    Well, this is why you go to an IRB before starting the research. Then you would know.. – Jon Custer Nov 23 '20 at 20:02
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At least at my institution and I suspect at most of them, the IRB tells you when your survey doesn't need full IRB review because it is legally exempt (often through an expedited process). You don't get to skip IRB entirely because you don't think it's needed (unless your institution says this is the case, or sends you in an alternate path to determine exemption, like some other not-really-an-IRB-committee).

You also might be saved if you can operate under some sort of blanket exemption from IRB for a category of work. For example, courses for students might have such a protocol that allows review to be skipped as long as it fits in certain parameters (basically they've already gotten acceptance for a range of studies that fit those parameters).

You'll have to contact your IRB, and likely beg them for forgiveness. It doesn't matter what we think at all. See also here and another useful Q&A that applies to your question.

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    It isn't just what you get back from a survey that could be problematic. Some questions could actually be triggering of certain conditions. Yes, you must talk to IRB. And, unfortunately, the IRB often can't "bless" things already done. I'm pretty sure there is a specific rule about that. – Buffy Nov 23 '20 at 20:17
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    @Buffy As far as I am aware the answer is always "it's up to IRB", including post-hoc-blessing, when there isn't a legal barrier to that decision. That said, "up to IRB" literally means it is up to them, and as you say it is entirely up to them to decide "No." And yes, good point about the hazards of surveys - anonymity isn't sufficiently protective, questions themselves may need review even if the responses were never to be saved. Informed consent is another key pillar. All of this is why you always involve IRB. – Bryan Krause Nov 23 '20 at 20:50
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    Wrt to informed consent, one could imagine a situation where the researchers give the impression answering is mandated by their employer, whether accidentally or not. This would be inappropriate. – Azor Ahai -him- Nov 23 '20 at 20:53

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