"Robert J. MacG. Dawson" wrote:
> 
> Jerry Dallal wrote:
> 
> > Since data are being collected from individual human subjects for
> > research purposes, IRB review is necessary.  The payment might be
> > viewed as a finder's fee, which is often considered unethical
> > because it compromises informed consent.
> 
>         No, data are *not* being collected from individual human
> subjects for research purposes; they are being collected for other
> purposes and then used for research purposes. 

<snip>

They may very well be exempt from IRB approval, but it's up to the
IRB to make the determination.  That's why I said "IRB review"
rather than "IRB approval".  I suppose I could have said that the
information "might be considered data collected for research
purposes".
.
.
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