Hi @eleonora.marocchini! Thanks for reviving this conversation (I think @msundukova is also interested in this topic). The IGDORE board has spent a bit of time looking into this, but we have not been able to come up with any options for providing ethical review for studies on subjects outside of Sweden (where IGDORE is legally based). The guidance for the IGDORE Code of Research Conduct states:
adhere to the ethical codes for research activities in which human subjects and animals are involved;
Research subjects must be protected, and any harms should be balanced against the benefit the research is expected to provide. It is the responsibility of researchers to know the regulations for ethical review requirements in the country where their research is conducted and apply for ethical review if it is necessary for their work to comply with national legislation.
If an IGDORE researcher is conducting a study on participants outside of Sweden then we can provide a funder with a letter stating the ethical review of the study by IGDORE is not possible, and that we will require confirmation that ethical approval has been obtained (or is not required) in the participants’ country before approving expenditure from the grant.
Some other resources I have come across that provide context for the difficulty of ethical review for transnational studies:
http://www.eurecnet.org/information/index.html is a good reference point for the national ethics committees across Europe. Unfortunately, funder requirements for ethical review seem to be largely driven from the perspective of international multi-site medical studies, where there will be a local partner in the medical centre in each country who each submits an application to their local ethics committee. For instance, the Wellcome human research guidelines says:
Ethical approval
Before research begins, researchers must have in place:
- ethical approval in every country where any part of the research will be carried out (this includes approval from their administering organisation if it’s based in a different country and the organisation requires it)
- the relevant regulatory and ethical approvals for every site where research will be carried out
- appropriate governance mechanisms.
I saw similar requirements on the websites of a few different UK universities, so I think this is fairly standard. It seems reasonable in the case of medical studies, but might be excessive for low-risk social science studies. For instance, the article “Only Applies to Research Conducted in Sweden…”: Dilemmas in Gaining Ethics Approval in Transnational Qualitative Research describes two case studies where researchers in Sweden had real difficulties in meeting funder requirements to get ethical approvals to conduct transnational online surveys:
The national circumscription of the ethics approvals involved (“Only Applies to Research Conducted in Sweden…”) meant that both researchers were required to seek ethics approval in all the participant countries in which they were going to conduct their research.
Further, Ethical review procedures in international internet-based intervention studies describes the wide variability in national requirements for ethical review of a transnational study on an online mental health-based intervention:
the Association of Internet Researchers (AoIR), which incorporates an Ethics Working Committee of international ethicists and researchers aiming to ensure that ‘research on and about the Internet is conducted in an ethical and professional manner’ (Association of Internet Researchers, n.d.), does not provide information about the ethical approval procedures in case of international internet-based research. The European Network of Research Ethics Committees (EUREC) only provides information regarding EU legislation for onsite clinical trials on medicinal products for human use, stating that in a multinational multi-centre trial, an ethical opinion of a REC in each participating country would be required (European Network of Research Ethics Committee, 2012). A European initiative on other types of clinical research than clinical drug trials, such as observational, survey or psychosocial or behavioral intervention studies is lacking (Veerus et al., 2014).
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Based on the guidelines and examples so far, it seems obvious for researchers to approach ethical review committees of participating institutes in international studies when physical activities are involved, such as providing study drugs or taking a blood sample. However, for international internet-based studies that take place solely online, it seems less obvious to apply for ethical review procedures in multiple countries.
Even the analysis of datasets in a transnational context can be difficult. A researcher analysing non-sensitive physiological data was unable to transfer a grant to IGDORE because we could not provide an ethical review as the data came from people outside of Sweden (even though ethical review had already been done during data collection, and possibly again for the analysis by the institution that hosted the grant initially). The article Ethics review for international data-intensive research notes:
research ethics committees (RECs) have been guided by ethical principles regarding human experimentation intended to protect participants from physical harms and to provide assurance as to their interests and welfare. But research that analyzes large aggregate data sets, possibly including detailed clinical and genomic information of individuals, may require different assessment. At the same time, growth in international data-sharing collaborations adds stress to a system already under fire for subjecting multisite research to replicate ethics reviews, which can inhibit research without improving the quality of human subjects’ protections
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Data-intensive projects often raise ethical concerns for which RECs have little guidance. Data can be collected from consenting participants at one site but stored, analyzed, or linked with data sets elsewhere. Data are typically stored for long periods and can be reused and (re)linked. Particularly problematic is that perceived and legislated ownership of data and the responsibility to authorize data sharing varies across jurisdictions.
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Ethics review for data-intensive international research should be founded on at least two principles. First, projects imposing similar risks on research participants should be subjected to similar levels of scrutiny by all RECs. Second, if we assume that procedural and regulatory alignment is in place, once an ethics review opinion has been provided, each jurisdiction should not require further de novo review.
Some new options for ethical review in low-risk settings are starting to take shape:
The ethics project aimed at non-medical researchers with a somewhat multinational focus that I know of is PRO-RES. My understanding is that this provides a collection of ethical codes and guidelines from across Europe, but I do think that it provides ethical review. @HelenKara wrote about her experience working on the project here: https://helenkara.com/2022/02/03/ethics-codes-and-guidelines/
The Social Research Association (UK based) also recently began offering an ethics appraisal service:
The service is designed for organisations and individuals who wish to have an independent ethical review of their research proposals, and can’t access this another way
Although they stress:
This service is not a REC (Research Ethics Committee) and does not ‘approve’ research - it offers expert advice and consultancy on a key aspect of research practice. Clients are welcome to cite their use of this service, but must not misrepresent it as a REC, or as having given approval.
(The Aotearoa Research Ethics Committee provides a similar service based in New Zealand)
Finally, our friends at the Ronin Institute (US based) recently developed a Human Subjects Research Policy and I believe that they have can provide exemptions for low-risk research (@arika.virapongse - is this exemption limited to studies done on subjects in the US?).