May state agencies disclose the identities of potential subjects without their written authorization?
If subjects will be identified through agency records and will be contacted for purposes of the research, you should assume that their written authorization will be required for the agency to disclose their identities and contact information to the researchers. If the researcher documents that the general criteria in state law and federal regulations for waiver of authorization are satisfied, the Review Board may consider approving a prior notification procedure in lieu of obtaining a written authorization to disclose subjects’ identities for study recruitment. The prior notification procedure must include provisions for prospective subjects to decline permission for the agency to disclose their identities to the researchers. Information needed for the IRB to approve a waiver of authorization is requested in the WSIRB Research Application, Appendix I, Section 4.
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