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IRB and GDPR Compliance for Human Subjects Research Recordings

Research interview recordings contain sensitive personal data. Complete guide on IRB and GDPR compliance for researchers working with participant recordings.

Research interview recordings are personal data under GDPR. They contain participants' voices, opinions, and potentially sensitive information. Incorrect handling can invalidate the project and incur sanctions.

GDPR
Art. 9: sensitive data requires explicit legal basis
4%
of annual turnover, maximum GDPR penalty
72h
to notify a data breach to the supervisory authority

Legal Basis for Recording Research Interviews

In academic research, the usual legal basis under GDPR is public interest (Art. 6.1.e) or explicit consent (Art. 6.1.a). Most university ethics committees require informed consent for recordings.

What consent must include

  • What data will be collected (audio/video recording)
  • What it will be used for (specific research project)
  • Where it will be stored and for how long
  • Who will have access to the recordings
  • Whether third-party tools (including AI transcription) will be used
  • Right to withdraw consent

Critical point: if you use an external transcription tool, participants must know at the time of consent. Add a specific line: "Recordings may be processed by AI transcription tools. Data is encrypted and not retained beyond [X] days."

Requirements for AI Transcription Tools

Before using any transcription tool with research data, verify: Where is data processed (preferably EU)? Is a DPA available? What is the audio data retention policy? Is data used to train AI models?

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