The researcher shall not ask institutions to directly identify potential subjects for a research study. Rather, the investigator shall ask an intermediary (doctor, case worker, school administrator) to first approach potential subjects (or their guardians, as appropriate) and inform them about the research. If a potential subject agrees to participate, the intermediary should provide her/him with the information necessary to contact the researcher, in such a way that the institution is unaware whether the subject chooses to participate in the research. The intermediary should not obtain consent from potential subjects.
The researcher shall not ask institutions to release records or anecdotal information either for the purposes of identifying subjects, or for examination by the investigator, unless this information is public. An investigator wishing to examine records must first obtain permission of the subject via an intermediary. If a potential subject agrees to release his or her records, the intermediary should provide the information necessary to contact the researcher. This provision does not apply to records with all identifiers removed (see p. 12, exemption 4). NOTE: Approval from participating institutions (e.g., schools, agencies) must be on file with Research Compliance Services prior to recruitment.