IRB and legal info

Overview

Before you can run a study on CHS/Lookit, there are three things you’ll need to do:

Sign and return the Lookit access agreement (details below). This covers your entire lab. You only have to do this once.
Get IRB approval at your own institution (details below).
Get peer feedback on the study, and then have it approved by CHS.

Access agreement

What it is

In order to use CHS/Lookit for data collection (including posting studies that run on other platforms/video chat studies), the principal investigator (PI) of a research group must first sign an institutional agreement with MIT that lays out each institution’s rights and responsibilities. This may require review by a legal or contracts office or an office of sponsored programs depending on the institution.

The access agreement with a PI at a given institution covers all studies conducted on CHS where the approved IRB protocol at that institution names that person as the PI. (If that institution cedes to another institution for approval, that’s still okay.)

The agreement itself is short and closely based on Databrary’s agreement (with permission); the meat is in the Terms of Use you are agreeing to. Researchers should actually read the terms carefully: these are real content written by a real person and contains non-obvious information about ethical/privacy issues you may not have encountered in the lab. Note that we do impose standards that may in some cases be more stringent than your own IRB’s.

To make sure we’re all on the same page, we require that at least one researcher associated with each research group using CHS complete this quiz about the Terms of Use.

How to get it signed

If you are planning a CHS study, getting the access agreement signed should be your first step because it takes a highly variable amount of time (record so far is under two weeks, but it can take a few months). The access agreement doesn’t require any customization on your part - you just need to send it off to someone at your institution who’s authorized to sign on behalf of the institution.

First, check whether your institution already has an access agreement set up. You can check the list here or email childrenhelpingscience@gmail.com. If so, you’ll be able to just add yourself (newer form of agreement) or get in touch with the person who signed off previously (older form of agreement). If there were any modifications to the standard agreement made for your institution, you’ll be able to just use the modified form instead of having to re-negotiate the same changes.

If there isn’t an existing agreement, you’ll need to figure out which office to send it to for approval. Unfortunately the appropriate office varies by institution. If you’ve previously set up to use Databrary, try contacting the office that signed off on that. As examples, the following offices have approved the access agreement: Contracts, VP Finance, Partnerships, University/Industry Liason, Department head, Provost, Sponsored programs.

In general, you do NOT need to have an IRB protocol to use CHS before the access agreement can be signed. In some cases, though, the office that signs the agreement may ask that you obtain ethical approval first.

The one exception to this process is that researchers at MIT, completing studies approved by MIT’s IRB, do not require the signature of an MIT authorized signer. However, the MIT PI still needs to sign and return the agreement.

Correspondence between access agreements and CHS Labs

In general, each Authorized Investigator on an access agreement should correspond to exactly one Lab on CHS, which makes it far more straightforward to ensure that everyone’s actually covered.

Each Lab must be associated with at least one agreement. (E.g., suppose Jill is a PI at Science University and has signed an access agreement, and Joe is another PI at Science University who has not. We cannot approve Joe’s Lab on CHS to test - even if he tells us that his work will always actually be covered under Jill’s IRB protocol.)

However, if multiple PIs at your institution are closely affiliated (e.g. a lab jointly headed by two professors, or students all serve as PIs on IRB protocols in your department) please go ahead and create a lab listing multiple PIs and just let us know. We’d need an access agreement for each PI, and would expect all studies conducted by this lab to be covered by an IRB protocol listing at least one of those PIs.

If your institution requires changes

We have generally been able to accommodate requests for minor changes to the agreement as required by universities’ legal departments (e.g. when they are legally unable to agree to MA governing law, or to allow UK ethics committee approval in addition to “US-equivalent” IRBs).

If it looks like some clause would be a deal-breaker for your institution, please get in touch with CHS staff (childrenhelpingscience@gmail.com) and general counsel lawyer Jason Baletsa (jbaletsa at mit.edu) for advice.

Please note that approval of changes happens on the MIT General Counsel office’s timeline, which is not under CHS’s control.

Sending it to CHS

Once you have the user agreement signed by the PI and institution’s authorized signer, please:

Make sure you or someone in your group has completed this quick quiz about the Terms of Use
Send the PDF of the signed agreement to childrenhelpingscience@gmail.com, noting that you have also completed the quiz

Ethics approval for CHS studies

A researcher using CHS applies to their own institution’s IRB for approval. Except for our involvement in a small set of initial studies, MIT is not considered to be engaged in human subjects research by running CHS.

You can find resources for writing your IRB protocol here. You will likely need to give a brief overview of how data collection on CHS works and what protections are included for participant data.

CHS may request a copy of the approved protocol at the time a study is submitted to run on CHS. (In general we don’t - we aren’t looking to get into that much paperwork. This is mostly if we have any concerns or you’re getting permission to do something unusual.)

Responsibilities of researchers

Everyone:
- Protect your CHS account credentials. You are responsible for any access to participant data on CHS via your account. You should choose a strong password, change it regularly, and never share it. (Share access by adding another researcher to your Lab - not by sharing a lab account password.)
- Promptly report any breach or potential breach of participant information that you become aware of, both to CHS and to your local institution.
PIs:
- You are responsible for the actions of anyone who’s conducting research on CHS under your access agreement. Ensure that anyone added to your Lab on CHS understands any rules in the Terms of Use that apply to what they’ll be doing. (E.g., make sure an RA tasked with approving consent and contacting families with compensation understands when it’s ok to withhold compensation, when to approve/reject consent, etc. Make sure someone helping with analysis understands which fields must be omitted from published data.) You may choose to create your own training materials based on the tasks they’ll actually be doing - please share these if so!
- Ensure that people who are no longer in your lab are removed from your Lab promptly.
Study admins:
- Ensure you have current IRB approval for your study before beginning ANY data collection on CHS. Promptly pause the study if approval lapses.
- Ensure that anyone with access to participant data for this study is listed on the appropriate IRB protocol. Promptly remove permissions for anyone who is removed from the IRB.
- Assign minimal appropriate roles for each person who needs access to your study.

Privacy policy

Both researchers and participants are covered by the privacy policy.