Guidelines for Media Projects Involving Human Subjects

Media production and human subjects research that capture individuals’ visual and/or vocal identity are sensitive matters. The rapidly-diversifying means for both recording and disseminating such materials makes this arena of human subjects work all the more complex. Such participants are not fictional characters, but people whose rights to privacy, informed consent, and fair representation are in the hands of a researcher or media maker. It is the researcher’s/media maker’s responsibility to think through the potential risks to subjects associated with participation in the project and to communicate these to subjects prior to recording.

Many of these endeavors blur traditional distinctions between research, journalism, and art. Occidental College has therefore worked to define specific criteria that determine if a project is subject to Human Subjects Research Review Committee (HSRRC) review. The College also has specific practices regulating media production separate from HSRRC approval, and relating to liability and risk management. Any student undertaking a media project must have a faculty advisor versed in the necessary technical and ethical methodologies.

PART I. RESEARCH PROJECTS

Research involves systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalized knowledge. Projects requiring HSRRC review and approval include:

A. Media projects intended for public use

Media projects (video, photography, or audio recordings) intended for public exhibition or distribution involving any of the following need to be submitted and approved by the Occidental College HSRRC prior to filming/recording, using the APPROVAL REQUEST FORM FOR MEDIA PROJECTS INVOLVING HUMAN SUBJECTS:

Protected categories of subjects: Such categories include minors (under 18 yrs), prisoners, those with a legal guardian, or any subjects unable to provide informed consent prior to shooting.

Expectations of confidentiality: This refers to any instance where you intend to offer assurances to a subject that despite the public dissemination of the project, their identity will somehow be protected or withheld.

Topics raising issues of confidentiality: Projects that involve sensitive subject matters that constitute potential risk to the subject, whether that risk involve the inquiry process itself, the handling of raw footage/recordings, or the distribution/dissemination/exhibition of the finished piece.

Topics or methods involving safety concerns: These concerns refer to any recording or exhibition practices that will potentially expose the researcher or the subjects to physical harm, retribution, or legal consequence.

Topics or methods requiring cultural sensitivity or specialized knowledge: Such concerns come into play if your recording involves travel to, or engagement with, a community or culture with specific religious, moral, legal, or social restrictions around media production, approaching subjects, or the specific topic you’re investigating.

Any use of deception: This refers to whether or not your methods involve the deception of subjects in any fashion, recording subjects without release or informed consent, or the withholding of information about the project’s topic, intended use, or yourself.

Inability to follow standard informed consent/release form processes:There are valid instances when language, literacy, or confidentiality and safety concerns will prevent the standard written informed consent/release form processes, but alternative measures will need to be thought through and approved.

All such media projects also require a customized INFORMED CONSENT FORM FOR MEDIA PROJECTSto be submittedfor review and approval. A template is included on the HSRRC website.

B. Media projects not intended for public use

When video, photography, or audio recordings of human subjects are produced as part of a research protocol, with no public exhibition or dissemination of the material intended, then these materials constitute data, and the standard APPROVAL REQUEST FORM FOR STUDIES INVOLVING HUMAN SUBJECTS should be submitted to HSRRC for review and approval.

As with all data, researchers will be expected to detail the process for securing this data and maintaining the confidentiality of participants. Public dissemination or use of these recordings, even as part of research presentations in the classroom or at conferences, will likely not be permitted. A student undertaking such a research project must have a faculty advisor versed in the necessary technical and ethical methodologies.

All such media projects also require a customized version of the appropriate CONSENT FORM to be submittedfor review and approval. Templates are included on the HSRRC website.

Take Note:

In deciding whether to chose option A or B:If you think you might want the opportunity to screen any recorded media produced in your research publicly at a later date, be it at a conference, film festival, or online, it is far better to follow option A “Media projects intended for public use” and to secure broader permissions at the time of recording. It is very difficult to secure additional permissions for public exhibition at a later date.

Class Projects: For either option A or B, if the proposed research is a class project, the professor can submit the appropriate APPROVAL REQUEST FORM as the primary investigator on the project and then be responsible for educating students and administering the approved protocol for the class.

Responsibility: It is the responsibility of both the student investigator and the faculty advisor to review these guidelines and to address the questions asked on the appropriate APPROVAL REQUEST FORM. Please refer to the HSRRC website ( for details and the appropriate forms. For questions regarding the human subjects research review process, please send an email to .

PART II. NON- RESEARCH PROJECTS

Documentary projects involving human subjects that are not for research but intended for public exhibition or distribution (this includes presentation at conferences or gatherings, film festivals, posting on the Internet, or DVD/file-sharing) are not subject to HSRRC review and approval. Examples of projects that might fall under this category would be a promotional video about your department or documentation of a panel or guest speaker on campus.

Occidental’s safety and liability policies still require creation and use of a customized INFORMED CONSENT FORM FOR MEDIA PROJECTSby the media maker. A template of the consent form is available on the HSRRC website at

Student projects of this nature will require approval by a faculty advisor before production can begin. Though the raw footage/media and completed projects may in most cases be the property of the student producer, the faculty supervisor should keep copies of all signed INFORMED CONSENT FORMSfor the media project in a College office under lock and key for a minimum period of three years.

Students and faculty are responsible for determining whether their media project is being produced a) within the parameters of Occidental’s safety and liability policies and b) in accordance with any permitting policies on filming or recording in public space or on city/state property. Contact Rebecca Dowling, Director of Risk Management () for assistance.

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9/32/11