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Is secondary analysis of data human subjects research?

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Is secondary analysis of data human subjects research?

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Much research in the social sciences deals with the re-analysis of data often available in a “public-use data file”. This is known as “secondary analysis”. The goals of the Common Rule apply to any person who has the potential to be harmed because of a research project, whether or not the person is directly interviewed or identified through data collected by another researcher for a different purpose. Public use data files are normally stripped of identifiable private information or “de-identified. In this case, the research is exempt since no identifiable human subjects are involved.

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