IRB Policies and Procedures
Policies & Procedures
- An Overview
- Application Process and Deadlines
- Board Authority and Composition
- Board Determinations
- Closure or Withdrawal
- Continuing Review
- Deception or Incomplete Disclosure
- Departmental Review Boards
- Dietary Supplements
- Exempt Review
- Expedited Review
- Full Review
- General Data Protection Regulation
- Incentives in Research
- Informed Consent and Assent
- International Research
- Mandatory Reporting
- Mandatory Training
- Non-English Speaking Participants
- Oral History and Journalism
- Prisoner Research
- Records Retention
- Recruitment of Participants
- Reproductive Risk in Clinical Research
- Research Advisors
- Responsibilities of Investigators and Sponsors
- Revisions to Approved Research
- Separation of Principal Investigators
- Student Research
- Suspension or Termination
- Whistleblower Policy
Recruitment of Participants
Email messages, flyers, and other types of advertisements are often used to recruit potential research participants. Such materials must be submitted to the Institutional Review Board (IRB) or Exempt Review Committee (ERC) for review, along with an explanation of how and where they will be used. Both the IRB and ERC have an Advertising Template, which includes email, SONA and a flyer sample, on their websites and in IRBNet.
Advertisements used in research should:
- Indicate that the project is research
- State who is conducting it (investigator name and/or facility name)
- List the purpose or condition under study
- State eligibility criteria (in summary form)
- Provide a brief list of benefits, even if only to the field
- List time or other commitment required
- State the location of activities
- Provide contact information
- Not emphasize incentives
- Allow enough space for the approval stamp
If recruitment will take place via email message, the content of the email message must be submitted to the IRB or ERC, including the (1) subject line, (2) body of the message, and (3) a statement that the project has been approved by Marywood University's Institutional Review Board or Exempt Review Committee, following our advertising template's language. If an investigator plans to attach a flyer to an email message, the body of the message can be shortened to eliminate redundancy.
With email use, the investigator must explain if:
- Someone at the location will forward the email message on the investigator’s behalf
- The investigator will post to a list-serve without seeing individual email addresses
- The investigator will obtain individuals' email addresses and transmit messages directly
If obtaining actual email addresses to directly message, the investigator must state whether the message will be sent through his/her (1) own, private email account, or (2) within a survey platform, where survey responses can be traced.
If emailing directly through a private email account, an investigator must utilize the email's blind copy (Bcc) feature to maintain all participants’ privacy. Note that use of a survey platform to transmit email recruitment messages may result in identification if unique survey links are created and sent to individuals. If anonymity is desired or required, one, general survey link should be generated for all, so that IP addresses are not captured.
If recruitment will take place via a social media site, the content of the announcement must be submitted, including sufficient detail about exactly how it is being posted and where it will appear. The investigator must indicate whether the method is "private" or "public" in terms of the site's parameters, and whether or not commenting will be disabled or comments will be monitored. Some examples are:
- Facebook: From which profile you are posting (personal profile, a "page" for the study, Marywood's official account, etc.)
- Facebook: Text posted to personal wall, organization page or group
- Facebook: Flyer uploaded to personal wall, organization page or group
- Facebook: Combination of text and flyer posted to a personal wall, organization page or group
- Facebook: Formal, purchased advertisement
- Facebook: Messenger communication to friends or to a groups' members
- Facebook: Post to stories
- Instagram: Image, image with text, "bio" on profile, stories, direct message, etc.
- Twitter: Image, image with text, personal message, etc.
Recruitment Permission - Required Letter
Investigators recruiting participants or accessing data at certain locations (e.g., doctors’ offices, hospitals, schools, universities, businesses, at events, etc.) must secure and submit a permission letter(s) from an appropriate official(s) at each location being used. All permission letters must be presented on the granting entity’s letterhead, be hand signed by the authorized official, show the official’s title and contact information, and state that the official is aware of the research and agrees to grant access to participants or data. Please see the IRB’s permission letter template. (Note: Officials must not send the permission letter directly to the IRB or ERC. The official must send it directly to the investigator, who in turn must submit it to the IRB or ERC with all other application materials via IRBNet.).
There may be circumstances where a formal letter or letter on letterhead may not be the norm, such as:
- Private Business Locations: In instances where advertisements are being posted at a private business which allows such posts without obtaining some type of permission (e.g., supermarket bulletin board), a permission letter may not be required; however, investigators need to identify the specific location(s) and describe each location’s policy and/or reason for not securing a letter.
- Public Locations: In instances where advertisements are being posted publicly (e.g. library), a permission letter may not be required; however, investigators need to identify the specific location(s) and describe each location’s policy and/or reason for not securing a letter. Keep in mind that even some public locations have policies about advertisements, and many municipalities have ordinances prohibiting flyer posting in specific locations.
- Social Media or Other Web Locations: In instances where advertisements are being posted to social media (e.g. Facebook, Twitter, etc.) or other web-based platforms (e.g. online forum), a permission letter may not be required, unless the site is part of an official organization or business which would typically utilize formal business communications; however, investigators need to identify the specific location(s) and describe each location’s policy (e.g. group rules) and/or reason for not securing a letter. It is also important to understand and follow the site's Terms of Service.
- No Letterhead: In instances where a small business or organization does not have letterhead, the IRB or ERC may waive the letterhead requirement, provided that the investigator adequately explains why it was not available. A signed permission letter will still be required.
Permission is also required for recruitment or data access on Marywood University's campus. Please see our Recruitment Permission Chart for further information.
Access to Marywood University's Email Distribution Lists
After approval has been granted by the appropriate Board or Committee, investigators wishing to access a campus e-mail distribution list in order to send their recruitment message must contact Emily Zocchi at email@example.com. The investigator must supply Ms. Zocchi with the (1) final IRB or ERC approval letter, (2) the recruitment permission letter stating to what lists the investigator needs access, and (3) the approved email recruitment message. No other individuals should be contacted for access unless a smaller, specific list not managed by Ms. Zocchi is being used (e.g., Veterans' list, list maintained by a department for specific majors, etc.).
Access to Marywood University's Official Social Media Pages
Instead of creating your own event or group page, the Marketing Department requests that you post to its official Marywood University page. With tens of thousands of likes and followers, it will receive much more exposure, resulting in greater participation. After approval has been granted by the appropriate Board or Committee, investigators wishing to access Marywood University's Official social media pages must contact Christa Ann Vinciguerra, Digital Marketing Specialist, at 570-340-6019 or firstname.lastname@example.org. The investigator must supply Ms. Vinciguerra with the final IRB/ERC approval letter, the recruitment permission letter stating the population targeted, and the approved announcement(s). No other individuals should be contacted for access.
Access to Marywood University's Bulletin Boards
After approval has been granted by the appropriate Board or Committee, investigators wishing to post flyers on campus must visit the Office of Student Engagement (OSE) in the Nazareth Student Center (Room 107) to have their flyers stamped by OSE. This is OSE's campus policy, and its office reserves the right to remove flyers that have not been appropriately stamped.
08/19/2015 - Updated information about permission letters
04/29/2016 - Updated temporary contact person for access to email distribution lists
08/05/2016 - Removed temporary contact person for access to email distribution lists
03/29/2017 - Updated email requirement to include subject line
07/28/2017 - Clarified email list access outside of OIT
08/16/2017 - Removed instruction to contact Ms. Nealon for department email lists
12/13/2017 - Updated Social Media contact
04/04/2019 - Updated Marketing Department contact and social media page information
11/07/2019 - Updated policy relating to Social Media and email information
02/26/2020 - Updated list-serve access contact
02/27/2020 - Updated Facebook methods and information needed for email recruitment
10/15/2020 - Updated list-serve access contact