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IRB Compliance

  1. Does the ModernThink Higher Education Insight Survey© meet IRB requirements?
  2. If a review is needed, does the ModernThink Higher Education Insight Survey© qualify for expedited IRB review?
  3. How does ModernThink protect the confidentiality of the survey data?
  4. Who can I contact with additional questions about the ModernThink Higher Education Insight Survey or ModernThink Institution Questionnaire?

1. Does the ModernThink Higher Education Insight Survey© meet IRB requirements?

Each higher education institution has its own IRB procedure. In our experience, the faculty and staff survey is exempt from IRB requirements pursuant to Title 45 of the Code of Federal Regulations, Public Welfare, Section 46, Protection of Human Subjects because it is a confidential survey. Specifically, exemption number two of 45 CFR 46.101(b) provides in relevant part:

(2) Research involving the use of educational tests (cognitive, diagnostic, aptitude, achievement), survey procedures, interview procedures or observation of public behavior, unless: (i) information obtained is recorded in such a manner that human subjects can be identified, directly or through identifiers linked to the subjects; and (ii) any disclosure of the human subjects' responses outside the research could reasonably place the subjects at risk of criminal or civil liability or be damaging to the subjects' financial standing, employability, or reputation.

During the ModernThink Higher Education Insight Survey process, data are collected in an anonymous and confidential manner and then tabulated and reported in the aggregate. Responses are never tied back to an identifiable individual. In addition, the demographic information is requested on strictly a volunteer basis.

As noted in FAQ #2 below, even though the survey is highly likely to qualify as “exempt”, some institutions still may require an expedited review. Consult your internal IRB requirements.

We have created a document for you to use internally to communicate with your Institutional Research / Institution Survey process available on the Downloads page.

2. If a review is needed, does the ModernThink Higher Education Insight Survey© qualify for expedited IRB review?

As noted in FAQ #1 above, it is our understanding that the ModernThink Higher Education Insight Survey is exempt from IRB review pursuant to 45 CFR 46.101(b)(2). Accordingly, for many institutions, no review is required. At some institutions, however, even exempt studies need to be reviewed. If that is the case at your institution, the survey should be eligible for expedited review.

Pursuant to 45 CFR 46.110, the Department of Health and Human Services has established and published as a Notice in the FEDERAL REGISTER, a list of categories of research that may be reviewed by the IRB through an expedited review procedure. Included among those categories is the following:

(7) Research on individual or group characteristics or behavior (including, but not limited to, research on perception, cognition, motivation, identity, language, communication, cultural beliefs or practices, and social behavior) or research employing survey, interview, oral history, focus group, program evaluation, human factors evaluation, or quality assurance methodologies. (NOTE: Some research in this category may be exempt from the HHS regulations for the protection of human subjects. 45 CFR 46.101(b)(2) and (b)(3). This listing refers only to research that is not exempt.)

The ModernThink Higher Education Insight Survey fits squarely within this category.

3. How does ModernThink protect the confidentiality of the survey data?

At ModernThink, we go to great lengths to ensure the anonymity of your employees' survey responses. Examples include the following:

  • ModernThink collects and stores all of the data on its secure servers.
  • All survey takers are provided with a confidential, toll-free hotline which they can call on an anonymous basis with any questions or concerns.
  • We only report data back to institutions when there are five or more participants in a particular demographic category.
  • Survey takers are reminded before responding to the open-ended questions not to include any self-identifying information.
  • Questions about demographics are strictly on a volunteer basis, unless otherwise disclosed to the survey takers.

Select Statement of Confidentiality for further details how we protect the confidentiality of your survey data.

If you have any questions about the Statement of Confidentiality, please call Kristina Naton at ModernThink. Kristina can be reached at 888.684.4658 ext. 104.

4. Whom can I contact with additional questions about the ModernThink Higher Education Insight Survey© or ModernThink Institution Questionnaire©?

Please contact ModernThink at 888.684.4658 or This e-mail address is being protected from spam bots, you need JavaScript enabled to view it .