Ethical research seeks to maximise benefit and minimise
The Economic and Social Research Council revised its ethical
framework in 2015,
and, for the first time, specifically referenced the importance of ethics
review for research using secondary data.
At the time, this created some concern about additional
burden throughout the academic sector, but guidelines explaining that
‘light-touch’ review was appropriate in some circumstances eg when using
aggregate data or data that are not identifiable, allayed those worries for the
For reviewers on ethical panels, experience is needed to appropriately
assess risk and suggest mitigation. For example, there is a risk of (unintentional)
re-identification of individuals in de-identified data when two or more datasets
are linked together following the Administrative Data Research Network (ADRN) model,
since additional information may generate more unique sets of characteristics
at more granular levels of geography. Allowing access in carefully managed
secure settings with the independent application of disclosure control to
outputs is one way to address this risk.
The academic sector has a tradition of transparent ethical
review and is generally well placed to accept and adapt to updated ethical
review requirements. Nonetheless, ethical review in many cases is still
considered to be a barrier to be overcome, rather than a cornerstone of
rigorous and robust research.
The necessity of ethical review for research projects supported
by the ADRN has led to the establishment of the National Statistician’s Data
Ethical Advisory Committee, which
is open to organisations that would not necessarily have internal ethical
review processes of their own.
In general however, non-academic researchers do not
necessarily apply ethical review to their use and re-use of secondary data,
identifiable, linked or otherwise. Strictly speaking, they are not obliged to
do so, once the requirements of the Data Protection Act (DPA), 1988, and other
relevant legislation are met.
The fact that something is legal does not mean that it is
ethical. (The converse may not be true either.) There is ongoing confusion and concern
about the re-use of personal data, yet people
still share information extensively with organisations and one another eg on
social media – despite not always fully appreciating what can and cannot subsequently
be done with it. At the same time, data that are publicly available can still be
personal data as defined by the DPA, 1988, and must be treated accordingly.
The Digital Economy Bill,
2016-17, which is currently progressing through parliament, and the General
Data Protection Regulation, to be
implemented in 2018, will soon need to be taken into account with respect to
research using secondary data, but neither is designed to answer ethical
Informed consent is one part of the answer to the “is it
ethical?” question, but it is not always feasible, especially for secondary
data research purposes, where the researcher may not know the identities of the
individuals in the study in the first place. The Information Commissioner’s
the view that consent is one but not the only gateway to legal and ethical data
sharing for research purposes, and it is very willing to engage in discussion
to facilitate research while ensuring that the rights of data subjects are
When secondary data research starts with ethics, we have the
chance to transform our mind set to really get to grips with the public
perception difficulties around re-use of data. We can even frame our early
thoughts from the first person perspective and ask ourselves how we would feel
if our data were to be used in the ways being suggested.
Ultimately, no matter what the data source, ethical
research, that is, research that is designed to do no harm, to be beneficial,
and to be fair and transparent, leads to increased trust and loyalty in
organisations and researchers, and over time enhances reputation and builds
Dr Emma White is the Associate Director of the
Administrative Data Research Centre for England, based
in the University of Southampton. She is also Head of Administrative Data for
NatCen Social Research. In
October 2016, Emma took up the role of Deputy Chair of the Market Research
Society’s Census and Geodemographics Group. She has a PhD in Mathematics, and
is a specialist ethics reviewer for the Faculty of Social, Human and
Mathematical Sciences in the University of Southampton.
Any views or opinions presented are solely those of the author and do not necessarily represent those of the MRS Census and Geodemographic Group unless otherwise specifically stated.