Overview: The purpose of this policy is to address privacy and confidentiality issues associated with visual and audio capture of human participants in research. This policy refers to any human subjects research that involves audio recording, video recording, audio and video recording, and still photographs extracted from video recordings.

Recording the voice and/or image of an individual creates a type of record that requires unique handling and storage, particularly if the content may be considered sensitive.  As with all research procedures, the dignity of human subjects should be respected.  Therefore, only what is necessary for the purpose of the study should be recorded.  Research subjects must be informed prospectively that such recording will occur, and be provided with information about the storage, confidentiality, and future use of the resulting recording.

If a research protocol involves the recording of research subjects, the Principal Investigator must include the following elements for consideration, in his/her protocol and informed consent form for submission to and review by the IRB:

Elements for consideration:

• Purpose and use of recording
• Specific identifiers that will be recorded (e.g., partial facial features, full facial features, subject’s name)
• Steps to avoid the inclusion of nonparticipants on the recordings
• People who will have access to the recording(s)
• Storage procedures, the storage location, and the duration of storage
• Procedures for controlling access to and use of the recordings
• Use(s) of the recording(s), including educational or analysis by external research group or future unspecified use
• State when and how recordings will be destroyed

The use of video/audio recording must be documented in the consent form. The IRB recommends researchers use headings in consent forms and create a separate heading for Video/Audio Recording. This section should identify the purposes and uses of the recording. It should provide information about who will have access to the recording and how access will be controlled. Storage information should state how long the investigator will store the recording and when and how the recording will be destroyed. If recordings will be used for educational purposes (e.g., research team meetings) this must be explicitly stated. Given that the identities of your participants remain on the recordings until they erased or destroyed, you must inform participants about the possibility that others may see the recordings or that the recordings may be used in additional research projects.

Additional considerations may be necessary for research that extracts photographs from video files, or research that records real-time video observations (e.g., Skype, Adobe Connect). PIs are encouraged to contact the IRB office to discuss the confidentiality, privacy and protection of this type of data.