Statement of ethics approval and consent
Prior to data collection, an assessment was made to establish the need for prior ethical review for the survey ‘Survey into COVID-19 Self Isolation Patterns in the Dental Team’. The survey was found to be exempt from UK ethical review for the following reasons:
Health Research Authority (HRA)
The Health Research Authority (HRA) ‘Does my project require review by a Research Ethics Committee?’ (V 2.0) was consulted in conjunction with the HRA online decision tool (http://www.hra-decisiontools.org.uk/research/).
The proposed survey was identified as research due to its transferable new knowledge to answer questions with scientifically sound methods and descriptive nature. (Transferable in this context means the findings of a qualitative study can be assumed to be applicable to a similar context or setting.) See Supplementary Material 1.
Accordingly a Stage 2 assessment was made using the online decision tool ‘Do I need NHS REC review?’ The online decision tool (http://www.hra-decisiontools.org.uk/ethics/) was employed for each country within the UK. The online tool established that the survey did not meet the necessary requirements for ethical review. See Supplementary Material, 2, 3, 4, 5.
To confirm the findings of this tool, the UK HRA document’ Standard Operating Procedures for Research Ethics Committees (v7.4, June 2019) was additionally consulted.
Paragraph 1.88 states (page 58),
‘Research involving only staff of health or social care services, who are recruited by virtue of their professional role, and healthcare market research are generally excluded from the scope of REC review (see paragraphs 2.3.13 - 2.3.15 of GAfREC).’
Under the UK HRA Standard Operating Procedures document, the proposed survey did not meet the necessary requirements for ethical review: the research only involved staff of health care services, who are by virtue of their professional role.
Governance arrangements for research ethics committees
Paragraph 2.3.14 of Governance arrangements for research ethics committees (GAfREC): 2020 edition (V2.0 FINAL 26.03.2020) states (page 11),
‘Research involving staff of the services listed in paragraph 2.3.4, who are recruited by virtue of their professional role, does not therefore require REC review except where it would otherwise require REC review under this document (for example, because there is a legal requirement for REC review, or because the research also involves patients or service users as research participants).’
Under GAfREC the proposed survey did not meet the necessary criteria for ethical review.
British Healthcare Business Intelligence Association (BHBIA)
The BHBIA Legal and Ethical Guidelines for Healthcare Market Research guidance (August 2019) was additionally consulted. This was found not to apply to the proposed survey.
GDPR
At the outset, and to avoid invalidating the data due to the survey link being available in the public domain, it was considered necessary to obtain GDC registration numbers for UK dental professionals. It is accepted that it is possible to identify an individual directly from the information being processed (GDC registration number). Whilst in the public domain, this information is classified as personal data and is subject to GDPR data protection principles.
The collection of this personal information was assessed under GDPR data protection principles The collection of GDC numbers was found to be ‘adequate, relevant and limited to what is necessary in relation to the purposes for which [it is being] processed’.
Consent
To determine the level of consent required the NHS HRA document ‘Applying a proportionate approach to the process of seeking consent’ (Version No. & Status: v1.02 03.05.2018 FINAL) was consulted.
Paragraph 2.6. Consent in postal/self-completion surveys states (page 16),
‘Where identifiable personal data is collected, and ‘consent’ used as the legal basis for the purposes of compliance with the General Data Protection Regulation (GDPR), then the questionnaire/survey must also include some means by which the participant may actively signify their consent.’
In the proposed survey, this was achieved by providing an explicit consent statement on the landing page:
“*For UK dental professionals
In order that the results of this poll are valid, it will be necessary to collect GDC registration numbers to ensure that there are no duplicate entries.
You can rest assured that this information will remain secure, and once the data has been tested for integrity, in the final analysis the results will be anonymised.
If you are unhappy or uneasy with providing your GDC number, then regretfully you cannot take part in this survey.”
Valid consent was accordingly obtained when survey participants provided their GDC registration number.
Data processing
All the information collected during the survey remained confidential, and encrypted (Bitlocker Driver Encryption). The pseudo-anonymous markers were removed after data validity was confirmed and prior to data-analysis. Only aggregate data has been reported.
Competing interests:
André Haigh declares no competing interests.
Ronuk Vasant declares no competing interests.
Dominic O'Hooley declares no competing interests.