How to get parental consent online
January 28, 2008 10:36 AM   Subscribe

[IRBfilter] I'm trying to set up an online survey for minors where parental consent can be accomplished online instead of via signed permission slips.

Has anyone done this successfully with the support of IRB? Any suggestions?
posted by k8t to Education (10 answers total)
How would you know that it was really a parent doing the parental consent?
posted by Steven C. Den Beste at 11:03 AM on January 28, 2008

I don't know about IRB, but what you're worried about, I think, is COPPA (Children's Online Privacy Protection Act). Here are the guidelines, including those around getting parental consent. A google search will obviously turn up much more.
posted by nkknkk at 11:22 AM on January 28, 2008

I'm not sure if COPPA applies to researchers, since the use is noncommercial (will the minors' answers be anonymous?).

Unfortunately, I can think of any studies on youth and internet use where the data was collected via a web survey. One way to approach it may be to do the recruiting through parent-oriented spaces, i.e. rather than recruit children directly, look for parents who are willing to involve their children. You might still need some identity verification, perhaps you could ask the parent to provide a drivers license number? You still run into the verification problem, but a DL is probably a good faith measure.

A lot depends on the character of your IRB and the content of your research. Are the questions of a personal nature? Are they potentially embarrassing? Is there an advantage to using a web survey that outweighs the potential risk/possibility of no parental consent? Also, what age range are you looking at--when I was at Texas the parental consent requirements for 13-17 year olds were different than under 13.

Sorry I don't have any good examples, hope this helps.
posted by DiscourseMarker at 11:45 AM on January 28, 2008

I think you will want to talk to your specific IRB, ideally before you submit anything. They'd usually rather have you call or email them in advance to sort things out. If you haven't already, go check out their website - my IRB, for example, has very detailed information on when you can get a waiver of signed informed consent.

Depending on your goal here, if you're just trying to avoid face-to-face interactions with people who may be far away, there may be other ways to accomplish it that the IRB will like better, such as consent by phone. Talk to your IRB; there's no weird consent situation they haven't already come across, a lot will depend on the specifics of your research, and they'll be able to guide you better than we can.
posted by Stacey at 11:58 AM on January 28, 2008

Response by poster: The students are in local middle and high schools, but we're concerned about parental permission slips being a big pain...
posted by k8t at 2:10 PM on January 28, 2008

Well, since you're working with local schools, maybe they have rosters with parent email addresses? It seems like that might be part of contact information they collect these days. Perhaps you could avoid the paper slips and send them electronically, which might actually get you a better return rate, be faster, and, if you have work email addresses, you would have a better argument that you actually are getting parents' consent.
posted by DiscourseMarker at 3:57 PM on January 28, 2008

IRBs can vary widely in their temperaments and policies (within the realm of the federal guidelines, of course), so seconding Stacey's advice to make an appointment with someone in your IRB office. A great approach is: "These are my research goals. And here are the practical constraints I'm working with. How can I create a consent process so that my research is ethical while still being practicable?" While you're there, go through your whole plan and find out if there are any other snags that may hold up your application.

The more I learn about this stuff, the more humble I become in the face of the complexities - so I do not claim to be any sort of expert. But I am on the IRB at my institution, and I don't know if I'd be much moved by the "parental permission slips being a big pain" argument. One of the considerations for altering standard consent procedures is that the research could not be practicably carried out without the modification (typically = would arguably tank the validity of the research in some way). More flexibility is often available in minimal-risk Exempt category research, but a study with minors automatically precludes that.
posted by shelbaroo at 6:57 PM on January 28, 2008

Another suggestion would be to brainstorm all of the ways you can think of to: 1. secure valid consent from parents; 2. convert that consent into an authorization code or link for youth participants; 3. get that information to participants; and 4. get their assent. Then play with different combinations for how that would work in practice, and rank each option in terms of workability for your plans. Then when you meet with your IRB rep, you've got some possible alternatives that you've thought through and know could work for you...and you can keep going down the list (starting with your most preferred combo) until the person you talk to says, "yeah, that might work..."
posted by shelbaroo at 7:14 PM on January 28, 2008

If you're working with schools, then you really do need to meet with the IRB. And probably also with a principal or superintendent from the school you're looking at, if you haven't already. The IRB has to deal with the federal regulations, but individual schools can generally impose whatever extra red tape they want to on top of that, and you've got no recourse for avoiding it. Whatever hoops the school wants you to jump through, you have to jump through. So you can work with the IRB to come up with a great system for avoiding permission slips, but if the school won't go along with it, you're out of luck.

Of course if you don't already have a particular school in mind, it gets doubly important to have a meeting with an IRB staff member - and when you call to set it up, specify that you're dealing with minors in a school setting and want to talk to someone who's familiar with that situation. They'll know the different schools in your area and which ones might be most welcoming to the sort of research you're trying to do without throwing up a lot of barriers.
posted by Stacey at 4:40 AM on January 29, 2008

Have you thought about transmitting the survey to the students via the parents? An email or a physical letter (if the URL is easy enough to type in)? That way, if it gets to the students, you know it's okay with the parents.
posted by NotMyselfRightNow at 5:06 AM on January 29, 2008

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