IRB review for SCF datasets?

Does analysis  of the Survey of Consumer Finances datasets require
IRB review at a university?

After discussion with an Ohio State University IRB Administrator, I
have concluded that one need not even apply for an exemption from IRB

It may seem silly to even ask this question, but the initial response
of the administrator was that I should apply for an exemption, even
after I repeatedly stated to her that anyone in the world can download
the SCF datasets.  I would like to hear from researchers at other
universities, but I suspect that the background of many people running
IRB offices is related to medical research, where the concern is about
subjects becoming ill in medical research.  It seems crazy to
waste people’s time for a review of analysis of a public dataset, but
compliance officers typically have little insight into the distinctions
involved with privacy issues in a survey you collect versus privacy
issues in a dataset such as the SCF, where a massive effort has been
completed to deidentify each SCF dataset.

At any rate, the crucial issue for a public dataset is whether it is
“coded” — which mystified me initially in my emails with our IRB
officer.  The meaning of this term has to do with whether there is
a code or key that would enable a researcher to obtain the identify of
a case on the dataset.

The statement given to me by our IRB administrator was:

“If the data is not coded but is deidentified then no agreement is
needed except for the determination of “not human subject”. In this
case no IRB review or exemption from IRB review is needed.”

I posted a question on the Federal Reserve’s web site, and the response
on July 31, 2006 from Gerhard Fries was:

“There is no direct key or identifier type variable in the data
set.  There is an ID variable, but that is randomly generated
between 1 and the number of households in the data  set>.”

He also noted that “the SCF is approved by the University of Chicago

Sherman D. Hanna

Professor, Ohio State University

Consumer Sciences Department

1787 Neil Avenue

Columbus, OH 43210