[IPAC-List] IRB consent for selection research

Fri Jun 28 13:36:53 EDT 2019

I agree completely with Michael and he is much more precise and eloquent
than I. Plus, in this age and era of electronic or online applications, we
often just include in the cover page that some of the data analysis is
being carried out be a center at the University, give the relevant IRB
information or contact information if their is a concern or question, and
then indicate that clicking to continue indicates consent. Of course, I do
not know if you are going to be collecting this information online.

Dennis

On Fri, Jun 28, 2019 at 12:44 PM Blair, Michael <Michael.Blair2 at opm.gov>
wrote:

> Megan –
>
>
>
> In both the private and government sectors, it is common to administer
> selection measures for the purposes of research – namely collecting
> validation data.  In some instances, the measures are truly experimental,
> in that the results are not used in the hiring process.  In other
> instances, the measures are live (having prior validation evidence) and are
> periodically re-analyzed.  Another common scenario is to have unscored seed
> items embedded in an active assessment (fairly typical for CAT-based
> assessments).  The seed items may be slated as potential future items or
> they may be embedded as research items seeking to enhance the validity of
> the measure (for example, using an established set of items to gather
> construct validity evidence for instrument.  As Dennis points out, consent
> is given when the individual submits the application.  Based on the extent
> of the experimental measures, the applicant may be provided with some sort
> of notification and/or be allowed to opt out.  For example, if a particular
> assessment or the entire test battery is experimental, opting out may be an
> option.
>
>
>
> I realize that the private and government sectors are different from the
> academic sector, but I wanted to provide some perspective.  Similar to the
> academic sector, in traditional research projects that recruit subjects,
> informed consent would be required and the researcher would go through the
> equivalent of an IRB.  Hope this helps.
>
>
>
> *Michael D. Blair*
>
> *Lead Personnel Research Psychologist*
>
> *United States Office of Personnel Management*
>
>
>
> P: 202-957-5427 | M: 202-957-5427
>
> Michael.Blair2 at opm.gov | www.opm.gov/HRS
>
>
>
> *From:* IPAC-List [mailto:ipac-list-bounces at ipacweb.org] *On Behalf Of *Megan
> Paul
> *Sent:* Friday, June 28, 2019 11:11 AM
> *To:* Dennis Doverspike <dennisdoverspike at gmail.com>
> *Cc:* IPAC-List at ipacweb.org
> *Subject:* Re: [IPAC-List] IRB consent for selection research
>
>
>
> Dennis,
>
>
>
> Thanks for calling out the nuances in my question. For context, this is a
> large multi-university partnership for a federal grant. IRB
> responsibilities have been coordinated such that they rest with two
> different universities (depending on the type of data), neither of which is
> my own, which makes it even harder to predict. In addition, I wouldn’t be
> surprised if neither had encountered this type of circumstance before, so
> I’d like to do my best to learn what others have done in similar
> situations. I think that the more we know about alternative approaches, the
> more likely we’ll be to arrive at a decision that meets everyone’s goals
> when we talk with them.
>
>
>
> On the question of whether it constitutes research, I get hung up on the
> generalizability part of the definition. That part seems somewhat
> debatable. I can see the findings being generalizable in a very broad sense
> (e.g., constructs that predict performance in the job in question), but the
> specifics wouldn’t be shared and, even if we did, they wouldn’t
> automatically be applicable without further work in the organization
> anyway. So at this point, it’s more about the process, which is uncommon in
> the field we are working in. It could be a valuable contribution to a
> meta-analysis, though, which would make it feel more generalizable. My much
> bigger concern, though, is that if the IRB requirements are so onerous or
> obtrusive that applicants reconsider their desire to apply, decide to drop
> out when they otherwise wouldn’t have, or raise questions or objections
> about the fairness and validity of the hiring decision (whether or not the
> assessments played any role in that), the future of the project will be at
> stake, so we need to anticipate how to avoid that. So the distinction
> you’ve highlighted is an important one; I care less about debating whether
> it’s research than I do about whether it has the potential for negative
> practical implications.
>
>
>
> I had similar thoughts regarding #2 but thought I might be alone in that
> thinking, so I really appreciate your perspective. As for #3, I confess
> that it wasn’t on our radar. Again, because we have multiple universities
> involved, that could be even more complicated than it already sounds, but
> it’s clear that we should look into it.
>
>
>
> Thanks again,
>
> Megan
>
>
>
> *Megan E Paul*
>
> *Research Assistant Professor*
>
> University of Nebraska–Lincoln
>
> Center on Children, Families, & the Law <http://ccfl.unl.edu/>
>
> 206 S. 13th St. Suite 1000 68588-0227
>
> (402) 472-9812 <4024729812>
>
>
>
>
>
> *From:* Dennis Doverspike <dennisdoverspike at gmail.com>
> *Sent:* Thursday, June 27, 2019 7:34 PM
> *To:* Joel Wiesen <jwiesen at appliedpersonnelresearch.com>
> *Cc:* Megan Paul <mpaul at unl.edu>; IPAC-List at ipacweb.org
> *Subject:* Re: [IPAC-List] IRB consent for selection research
>
>
>
> Megan,
>
>
>
> You can always call me but you are really asking two separate questions.
> The questions are:
>
>
>
> 1. Do you and should you go through IRB, I assume a University or Center
> IRB, for a selection project?
>
>
>
> 2. Should job applicants provide informed consent?
>
>
>
> The answers are complex. I believe the answer to 2 is simpler, and for 1
> you might need to call me.
>
>
>
> For 2 - No, applicants should not provide informed consent. First,
> generally job applicants are seen as giving an implied informed consent, by
> the very nature of their being job applicants.  Further, collecting
> informed consent from job applicants involves another step and also
> increases the chances or odds they might be identified, depending upon your
> situation, so I would say no to informed consent for job applicants.  There
> is already a consent. Now, if the tests or assessment are outside the
> normal course of business, or involve extra work or time, then maybe you
> could make an argument, I would still say no, but maybe you could make an
> argument, or make an argument you should at least give them some
> information, but you could give them information without getting informed
> consent. Of course, the whole issue of informed consent as I said is
> totally separate from whether you need to go through IRB. However, this is
> a situation where my guess is an IRB panel would also say - do not get
> informed consent. That is what i have usually been told for selection and
> survey projects through the University. The informed consent adds a layer
> of intrusiveness to what is a normal part of getting or keeping a job, and
> you should not be adding a layer of intrusiveness.
>
>
>
> 1. Now we get complicated though. Do you even need to go through IRB? I
> would say that depends on your university. It also depends on how you are
> labeling your selection project, is it 1)research for publication - then
> yes probably IRB; 2) research for a thesis or a dissertation - then yes
> probably IRB; 3) a grant - then probably yes; 4) sales or service - I would
> say no. That is where it depends on your university set up, depending upon
> your university set up this type of work may be regarded as research, or
> sales and service, and they probably have existing rules on whether a
> project like this needs to be sent to IRB. Of course, if you do have to go
> through IRB, they will tell you if you need informed consent, and what type.
>
>
>
> 3. This is a big issue you do not mention. I know Omaha and Lincoln are
> public universities. And unless you are at a Foundation, which is separate
> from the University, then you are doing this research as a public entity.
> Because you are doing it as a public entity, you are probably subject to
> open records laws. So you might want to consider protecting the company and
> all of the applicant data by considering an NDA. Unless your University has
> rules that protect such research, although it might not be research as we
> discussed, or sales and service, from open records discovery, you probably
> want the company to request an NDA from you. Although I do not know
> Nebraska open records law law, that may help to shield you from open
> records requests. And does Omaha still have an applied center, you could
> talk to them as to how they handle it.
>
>
>
> You should probably just talk to the University, or if under a foundation
> the foundation's, attorney about these issue.
>
>
>
> Dennis
>
>
>
> On Thu, Jun 27, 2019 at 8:00 PM Joel Wiesen <
> jwiesen at appliedpersonnelresearch.com> wrote:
>
> Megan,
>
> I'll try to find an IRB submission that involved testing and send it to
> you.
>
> Joel
>
>
>
>
>
> Joel P. Wiesen, Ph.D., Director
>
> Applied Personnel Research
>
> 62 Candlewood Road
>
> Scarsdale, NY 10583-6040
>
> http://www.linkedin.com/in/joelwiesen <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.linkedin.com_in_joelwiesen&d=DwMFaQ&c=Cu5g146wZdoqVuKpTNsYHeFX_rg6kWhlkLF8Eft-wwo&r=KjD5c2R2iI-zrd1ViuTbBQ&m=At3mvRLtceoI3SoOGtT1pyGrEJbWjsYdra2UD9YKF2c&s=KD0TJNrPxTYnb8wsjJFFqGIXMdhE2sKg0Mfc0SxSpXg&e=>
>
> (617) 244-8859
>
> http://appliedpersonnelresearch.com <https://urldefense.proofpoint.com/v2/url?u=http-3A__appliedpersonnelresearch.com&d=DwMFaQ&c=Cu5g146wZdoqVuKpTNsYHeFX_rg6kWhlkLF8Eft-wwo&r=KjD5c2R2iI-zrd1ViuTbBQ&m=At3mvRLtceoI3SoOGtT1pyGrEJbWjsYdra2UD9YKF2c&s=zSTJPCnIap7GiSg9LmRW0ciCfsOF1Vv9fhmEbtxyI-c&e=>
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>
>
> On 6/27/19 5:42 PM, Megan Paul wrote:
>
> Does anyone have experience with having job applicants provide IRB consent
> to participate in selection research? We’ll likely be looking at a few
> objective measures (e.g., personality, emotional intelligence), an
> interview, and possibly a writing assessment. I’m anticipating that the
> usual IRB language will be expected, but it seems like a bit of a misfit
> for the circumstances. Results of the objective measures won’t be used for
> decision making until after validation, but the others will be used for
> hiring decisions. It’s possible that we can make a convincing argument that
> consent is not needed (i.e., that it doesn’t constitute research), but if
> we can’t, I’d like some idea of how to best handle it in a way that’s
> acceptable to applicants.
>
>
>
> Thanks in advance.
>
>
>
> *Megan E Paul*
>
> *Research Assistant Professor*
>
> University of Nebraska–Lincoln
>
> Center on Children, Families, & the Law <http://ccfl.unl.edu/>
>
> 206 S. 13th St. Suite 1000 68588-0227
>
> (402) 472-9812 <4024729812>
>
>
>
>
>
>
>
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> --
>
> Dennis Doverspike, PhD., ABPP
> dennisdoverspike at gmail.com
>
> *Principled Progress Through People Science*
>
>
>
> *Doverspike Consulting LLC:*
>
> HR Litehouse (DBA)
>
> Chief People Scientist
>
> Mailing:
>
> PO Box 1788
>
> Stow, OH 44224-0788
>
> 330-690-3534
>
> Email: dennisdoverspike at gmail.com
>
>
>
> *Personal:*
>
> Dennis Doverspike
>
> 3171 N. Dover Road
>
> Silver Lake, Ohio 44224
>
> 330-690-3534
>
> dennisdoverspike at gmail.com <dennis_doverspike at yahoo.com>
>
>
>
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-- 
Dennis Doverspike, PhD., ABPP
dennisdoverspike at gmail.com
*Principled Progress Through People Science*

*Doverspike Consulting LLC:*

HR Litehouse (DBA)

Chief People Scientist

Mailing:

PO Box 1788

Stow, OH 44224-0788

330-690-3534

Email: dennisdoverspike at gmail.com

*Personal:*

Dennis Doverspike

3171 N. Dover Road

Silver Lake, Ohio 44224

330-690-3534

dennisdoverspike at gmail.com <dennis_doverspike at yahoo.com>

The information is intended only for the person or entity to which it is
addressed and may contain confidential, privileged and/or a work product
for the sole use of the intended recipient. No confidentiality or privilege
is waived or lost by any errant transmission. If you receive this message
in error, please destroy all copies of it and notify the sender. If the
reader of this message is not the intended recipient, you are hereby
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transmission, immediately delete it and all copies of it from your system
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