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Review of Chapter 2.3 of the National Statement: Qualifying or waiving conditions for consent submission

ID: 
12
This submission reflects the views of
Organisation Name: 
Avondale College of Higher Education
Please identify the best term to describe the Organisation: 
Educational institution – tertiary
Personal Details
Specific Questions
1. Please comment on the following definition of ‘opt-out’:: 
The definition is what is consistent with the Avondale HREC application of it.
2. Please comment on the rationale provided for an opt-out approach (i.e. Section 3).: 
The rationale provided describes the need for an opt-out approach. A common example for section 3.2 relevant to our education institution is research that is conducted as a whole school class activity. Gathering explicit consent for this research from school parents creates extra paperwork and administration for the participating school. Section 3.3: we agree that an unacceptable statistical bias may be produced when a low response rate is received and that a sample population may appear more favourable to the researcher where explicit consent is only permitted.
3. Please comment on the proposed limited application of an opt-out approach (i.e. Section 4).: 
Section 4.1 and 4.3: agree, this is consistent with our view of its limited application.
4: Please comment on the flow chart (i.e. Section 4).: 
Identifies the process as we apply it.
5. Please comment on the appropriate mechanism for providing information to participants for the opt-out approach represented at box 6d of the flow chart.: 
Where identifiable data was present, reasonable attempts should be made to contact the participants to inform them of how the data will be used and potentially published.
6. Please comment on the proposed amendments to the National Statement (see Attachment A underlined and in red text).: 
Section 2.3.10d: in addition to the information provided to prospective participants, information about how the data will be published or disseminated would provide greater transparency for the prospective participant.
9. Can you provide examples where an opt-out approach may be useful?: 
For our institution, the opt-out approach is useful in large group situations e.g. school classes, church congregations where the research participation is no more than a normal activity or conducted during normal class or church times.
General Comments
Comments: 

Thank you for this opportunity of provide comment on the review of Chapter 2.3 of the National Statement.

Avondale's Research Committee and HREC normally prefers that the opt-out approach not be used for participants under 18-years of age, unless the HREC is convinced that there is no risk to the participants. Each research project needs to be reviewed on it own merit.

Page reviewed: 28 March, 2014