Having had a chance to look at the actual survey, I can kind of see how it could have been mistakenly determined to be exempt (no greater than minimal risk). It would have still been an incorrect determination based on the fact that the researchers were not collecting directly identifiable information and would not have had an honest risk/benefit analysis considered. The description of their crimes could potentially identify participants and would raise the risk level of the research to greater than minimal/full committee review and may even require a prisoner representative to be present.
One other thing that stuck out is although he says the data will be confidential, that really doesn’t mean much. He doesn’t say it’s anonymous or that data will be collected/stored without identifiers. If he’s emailing the survey from REDCap, I believe the researcher has to manually set the the survey not to collect or tie responses to email addresses.
I also noticed he doesn’t say in the beginning of the survey that the study has been reviewed by the IRB, only in the advertisements. That made me go look up DeSales IRB forms. Non-exempt studies require specific elements of consent, whereas exempt studies can use an information sheet that does not include all of those elements. DeSale only has a full consent template on their website, so I assume that they do not utilize information sheets that are not based on the consent template language, which his introductory text does not match. No risks or benefits mentioned, no way to contact the IRB… those are significant omissions.
Based on all of that, I’m going to bet that this wasn’t an IRB-approved study. If they approved this, they dropped the ball big time.