Institutions, companies, states, programs, etc. often evaluate their procedures or workplace environment in order to improve their outcomes. Researchers are hired as individuals qualified to collect data and offer consultation to these groups, which can also be a valuable resource of data for a researcher’s personal studies. It is important to distinguish the difference between an evaluation and a research study. For example, if a company is funding the study as part of an evaluation of its employees, the researcher has been hired as an evaluator for the company, and the data collected will be used only to evaluate the company’s procedures, then the Board considers this to be an evaluation and not a research study. The researcher is not required to submit a protocol to the Board. However, if the researcher intends to use the data beyond the employer’s evaluation (thus qualifying the evaluation as research), the researcher is required to apply for IRB review.
 
There may be instances where the employee may be required to participate in a work-mandated evaluation as part of his or her job, thus the employee may not be able to participate voluntarily. However, the employee is not obligated to be a participant in the research aspect of the study. In order to use this data, the Board requests that you do one or both of the following (depending on the nature of the data):

• Receive anonymous data or data stripped of identifiers.
• Allow the participant the option to opt out of the research study aspect of the evaluation. The participant would still complete the evaluation but would decide not to release their data to the researcher. For example, if the participant is completing a survey, include a question that asks if the participant wants to include that data in the study. If the study involves more in-depth data such as interviews or other identifiable information, the participant should be given the opportunity to consent and it may be less coercive to approach the participant after the evaluation is complete. In addition, make sure that the research portion of the procedure is explained by someone who does not have authority over the participants and that the participants are assured that their employer will not know that they participated in the research portion of the evaluation. Regardless of your procedure, the ultimate goal is that participants will understand that they can participate voluntarily without it reflecting on their job performance.

If the study is initiated by the researcher for research purposes, then the researcher will need to follow the following guidelines:

• Obtain the necessary permission to conduct a study at a workplace. You may be required to sign confidentiality agreements so that you are legally obligated not to divulge trade secrets, etc. For your protection and your participants’ protection, make sure that you are conducting yourself according to company policy and code.
• Protect participant confidentiality. As a general rule, it is best to collect the data in such a way that the employee’s supervisor(s) does not know who is participating in the study, nor does the supervisor(s) have access to the employee’s data. In the “Confidentiality” section of the consent form, inform the participant that his or her supervisor will not know that he or she is a participant in the study and will not have access to the participant’s data.
• Recruit participants discreetly. In most cases, recruiting participants should also be done discreetly. There may be instances where you will need a supervisor’s permission to contact a participant, and the participant will want to know that their supervisor will allow them to participate. It may be appropriate for a supervisor to draft a letter or announce your study in a staff meeting; however, the supervisor should not endorse the study or make anyone feel like it is a job requirement to participate.
• Be conscious of the employee’s time when you ask the employee to participate. Your study may burden an employee or cause them to lose productivity, which could affect their job. If your study involves aspects that could be completed at home, consider advising the participant to complete these tasks at home or off the clock. If the participants will be interviewed, it may be appropriate for you to conduct the interview before or after work and in an area away from the workplace. Make sure that the consent form outlines what is required of the participant and that the supervisor is aware of the time required to participate in the study.

The Board does not generally allow the researcher to use his or her own employees for a study except where the individual participant’s data cannot be linked to the participant’s identity. If the study is funded by the researcher’s company and the participants are required to participate as part of the job, the researcher cannot automatically gain access to this data because he or she is the employer. Even though the researcher may have access through his or her professional position, the above stipulations still apply.

If the study is funded by the researcher and is not part of the company’s initiative, the researcher should demonstrate to the Board that the study can be conducted in such a way that the participants will be able to participate voluntarily. Please understand that the Board may request that you use participants other than those whom you employ or supervise.