Guidance for Student Researchers

This guidance is intended for students who are conducting research and who may be unsure about whether they need to submit their research to the IRB.

IRB Video Tutorials for Student Researchers


The following video clips provide detailed information about student IRB submissions.

Do I have to submit?


Your first question might be, do I have to submit to the IRB? If your work meets the below criteria, it requires IRB approval before you can get started:

  1. You are interacting, observing, or conducting an intervention with people (“human subjects”); AND / OR

  2. You are collecting private and/or identifiable information about people; AND

  3. Your work is systematic; AND

  4. You want to contribute to generalizable knowledge


The words “systematic” and “generalizable” may be a bit confusing, but if you are working with four or more people, conducting a methodical study, and wanting or planning to use your research for more than a class paper or project, you meet the criteria.

Secondary Data Analysis and the IRB


You may wonder if you have to submit to the IRB if you will conduct a secondary data analysis or will otherwise analyze content. If you are working with people’s private and identifiable data, you have to submit to the IRB. Examples include accessing private social media data, school records, or medical records. If the data you will use is publicly available, you do not have to submit to us. Examples include accessing publicly available social media data, or survey data from an institution like the PEW Research Center, where anyone can download the data without an application process. If you’re unsure whether you have to submit, you can complete our Human Subjects Research Determination Form and email it one of the IRB’s Senior Analysts.

How Do I Submit to the IRB?


You submit your research through the IRB’s online application system. You can access a walkthrough of the HSERA system to help you navigate the application on the page below. Things to keep in mind:


  • Most, but not all, student research is reviewed under one of the exempt or expedited categories outlined in the federal regulations.
  • Penn policy mandates that only faculty can be listed as the Principal Investigator (PI) in HS-ERA. Make sure that you have a faculty member who is willing to serve as a PI before you submit.
  • You should list yourself as a “Study Contact” or “Other Investigator” in HS-ERA. If you fail to list yourself, you won‘t be able to edit your application in the future. Please don’t list yourself as “Key Personnel.” If you do so, you won’t be able to edit your application in the future.

What Do I Include in My Application?


You should answer all questions posed in HS-ERA using detailed plain language. The IRB wants information about what you will do, how you will do it, who you will work with, where you will conduct research, how you will maintain confidentiality, etc. The IRB doesn’t need excessive scientific background, nor the methodological underpinnings of your work— the IRB wants more logistical information about your research methods and procedures. In essence, do not copy and paste your thesis or dissertation into the application.


In addition to answering questions in HS-ERA, you should attach the following documents to your application. Even if you think your work will qualify for review under an exempt category, you are not permitted to self-exempt (per Penn Policy) and we need to review these documents:

  1. Consent materials (e.g., consent script or informational sheet)

  2. Recruitment materials (e.g., flyers advertising your research)

  3. Data collection instruments (e.g., surveys, interview scripts, or questionnaires)

  4. Other supplemental materials (e.g., educational materials, forms for working with vulnerable populations like children)

Additional Guidance


Below are additional guidance materials that may be relevant to student research.



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