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Research Ethics Board - Procedures for Delegated Research
Protocols
Procedures for Delegated Research Protocols
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Protocols that present only minimal
or very low risk to subjects are reviewed by the Chair
or a subcommittee of the Board. Minimal or low risk is
ordinarily taken to mean those risks normally
encountered in everyday life by the research subject.
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The
turn-around time upon receipt of completed submissions
that receive delegated review is generally within three
(3) weeks. Submissions that are incomplete or require
modifications will necessarily delay this process.
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There are three streams of delegated
review:
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Research projects involving
minimal risk that proposes a prospective collection
of data involving families or staff. The
appropriate authorization from the manager
responsible for the staff or the clinical population
involved in the study is required. Please use the
application form
Application Form for Prospective Studies involving
Low Risk to Families or Staff
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Retrospective chart
reviews/secondary use of clinical data. The
Application Form for Retrospective Chart Review and
Secondary Use of Clinical Data must be submitted.
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Databases. The
Application Form for Databases Analyses must be
submitted.
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Please submit
the original and one copy of the application,
protocol and applicable documents for review. Please
ensure that all questions are answered in full.
Materials should be double-sided and pages numbered
consecutively; collated in complete packages, and each
document stapled individually and then black-clipped or
bound in elastics in collated packages. Only complete
applications will be accepted.
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Guidance With
Respect To The Distinction Between Quality Assurance And
Research.
The Distinction between Quality Assurance and Research
The Interagency Advisory Panel on Research Ethics PRE has
provided guidance on the distinction between quality
assurance and research. The Panel states that quality
assurance studies may share characteristics with research
and in fact, may use scientific methods. In quality
assurance, however, the data are used to advance the needs
and functioning of the organization. By contrast, in
research, data are used to answer a scientific question.
The primary distinction between research and quality
assurance is therefore, in their respective objectives,
rather than the methods used. Studies that intend to
disseminate their findings beyond the organization are more
typically categorized as research. This is because it is
difficult to assert that the data will only serve the
internal purposes of the organization when there is a clear
intent to disseminate the results.
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Definition of Secondary Analyses of Clinical Data
The secondary use
of data refers to the use in research of clinical data
generally contained in health records and collected in the
provision of care. Common examples are patient records or
biological specimens, originally obtained or produced for
therapeutic purposes, but subsequently used to address
scientific questions. The ethical obligation to respect
privacy and confidentiality requires that researchers and
REB’s exercise caution in the secondary use of clinical data
toward research ends. The Provincial Personal Health
Information Protection Act of Ontario (PHIPA) sets forth the
following requirements in this regard:
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The scientific
question being asked is valuable and justifiable
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Appropriate
measures are being taken to protect the privacy of the
individuals, to ensure the confidentiality of the data,
and to minimize harm to subjects;
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The patients
regarding whom the data refer will not be directly
contacted by the researchers without their prior express
and informed consent
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Identifying
information will not be released to researchers outside
the hospital without the patient’s express and informed
consent
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Individuals
to whom the data refers have not previously objected to
such secondary use
The data being collected would normally be obtained in the
provision of care (section 29 (2)). As
a consequence, the REB must ensure that the research plan limits
its analysis to those data fields that would normally be
available in the health record (departmental or centralized
chart). If an investigator wishes to look at variables that are
supplemental to care (e.g., in many instances, this could
include race and SES), the individual’s express and informed
consent must first be obtained and the research plan approved by
the board.
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Database Analysis refers
to the use in research of data contained in a previously created
data set, whether it is retrospective or prospective. Database
projects often use the same data set to answer several, related
research questions. The REB requires that investigators submit
a general description of the project including all the elements
specified above (study rationale, identifiers to be retained,
etc.). The overall database project is reviewed under the
‘delegated’ stream (previously expedited review). In an
addendum to the application, investigators must describe each
publication or sub-study relating to the database. For
instance, in a database looking at job satisfaction of REB staff
(protocol number 00/00X), a study looking at the quality of life
of REB chairs would be treated as a sub-study (protocol
00/00Xa). In this example, the quality of life study would be
described in a one-page summary submitted to the Board for
approval.
Access to the database
should be limited to the investigator and his/her delegates as
outlined in the application. REB approval should be obtained
prior to any release of the data to other investigators.
These submissions require
the following:
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A duly completed
database application form, including the data abstraction
form or the list of data fields to be collected.
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A description of the
scope and purpose of the database
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Authorization from the appropriate division head from which
the database information would be obtained
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