This page describes research policies at Singh Psychology, PLLC, a private practice in Seattle, Washington, described hereafter as “Singh Psychology.”

Oversight of Research Activities at Singh Psychology

The person responsible for maintaining and adhering to these research policies at Singh Psychology is the Owner, Narayan B. Singh, hereafter referred to in these Policies as the Director of Research.

Relationship of Research to Singh Psychology’s Mission

Inviting my clients, consultees, students, or trainees to participate in research involves a dual relationship. It is my policy that my clinical and training responsibilities and missions always take priority over the research goals. Clients, consultees, students, and trainees at Singh Psychology are invited to participate in research but are not required to do so as a condition of receiving care or consultation or training at Singh Psychology. (I use the word “participant” in these Policies to refer to all of those types of research participants.)

If the research proves to conflict with the clinical or training goals, I will discuss the issue with the participant and arrive at a solution to the conflict that is acceptable to the participant. I will always consider the option of resolving the conflict by discontinuing the research with that participant. If the conflict is not quickly and easily resolved, I will follow the procedures outlined below in the section titled Security Breaches, Protocol Violations, and Other Adverse Events.

Training in Research Involving Human Subjects

All professional and administrative staff engaged in research activities at Singh Psychology, including management or analysis of data derived from these activities, will complete a course on protecting human research participants and obtain a Certificate of Course Completion. This training will be obtained through the National Institute of Health or the Collaborative Institutional Training Initiative, or a comparable organization meeting federal standards for protecting human research participants. Each individual engaged in research activities will renew his/her certification every five years at minimum and will provide a certificate of completion to Singh Psychology’s Director of Research. Everyone at Singh Psychology who is engaged in research will complete the required training before engaging in any research activities.

Ethical Review of Proposed Research

All research projects involving the collection or analysis of data obtained at Singh Psychology must undergo some type of review to assure that the project is legal and ethical.

Options for the type of review include: a formal Institutional Review Board review that meets Department of Health and Human Services (DHHS) standards; a review by a body of professionals convened for that purpose; a formal consultation from an expert in IRB issues; an informal consultation from a colleague or group of colleagues who is not involved in the research.

The level of review selected will be commensurate with the nature of the project. Factors to consider include: risk of harm, especially risk of loss of confidentiality by the participants, which is always a main concern; number of collaborators from outside organizations; ratio of benefits to costs of the research; burdensomeness of the research to the participants; concerns about coercion of participants; or other factors. Regardless of the type of review conducted, the review must be documented to show that relevant legal and ethical issues have been addressed.

Informed Consent

Individuals providing research data to Singh Psychology must always provide their explicit informed consent to participate in research. Informed consent procedures must include an “opt-out” option. Clients who decline to participate in research or who withdraw consent to participate in research after previously consenting will receive no penalties and no negative consequences to their treatment or eligibility to receive treatment at Singh Psychology.

Consent may be obtained and documented via a formal written or online consent document that meets DHHS standards. The Director of Research at Singh Psychology must approve the informed consent mechanism used, ensuring that the degree of explicit and detailed consent and process used for consent (e.g., online, phone discussion, face-to-face meeting) is commensurate with the level of risk posed by the research. Whenever there is uncertainty about the rigor and intensity of the informed consent process, the Director of Research will seek consultation with an Institutional Review Board and/or other knowledgeable professionals.

When a prospective research participant is under the age of 18, informed consent will be obtained from a parent or legal guardian, and to guard against coercion, assent procedures will be used.

Audit of Consent Documents

After the data are analyzed and before the study is presented or submitted for publication, the PI or someone that s/he designates will audit the consent documents to be certain that every participant included in the data set has provided consent for the research using the consent procedure agreed upon for that project.

HIPAA

The Health Insurance Portability and Accountability Act of 1996 designates businesses that file insurance billing electronically as HIPAA covered entities, and requires that they obtain a HIPAA authorization for research from research participants. Singh Psychology is a HIPAA covered entity, and therefore informed consent forms include language for obtaining HIPAA authorization for research from research participants.

State Law

Singh Psychology will follow laws in the State of Washington pertaining to conducting research with human participants.

American Psychological Association (APA) Ethics Codes

Singh Psychology follows the APA ethics codes, which provide guidelines for research, confidentiality, dual relationships, and other relevant issues, including with regard to sharing authorship and credit for the research.

For example, principle 3.05 of the 2002 ethics code states, “A psychologist refrains from entering into a multiple relationship if the multiple relationship could reasonably be expected to impair the psychologist’s objectivity, competence, or effectiveness in performing his or her functions as a psychologist, or otherwise risks exploitation or harm to the person with whom the professional relationship exists. Multiple relationships that would not reasonably be expected to cause impairment or risk exploitation or harm are not unethical.”

Malpractice Insurance Provider

At each annual renewal of its malpractice insurance, the Director of Research informs its malpractice insurance carrier that Singh Psychology conducts research involving human subjects.

Unpaid Research Assistants

Singh Psychology may use unpaid/volunteer research assistants (RAs) to assist with research tasks. I will take care to provide them with a useful training experience and not exploit their efforts. Like others engaged in research at Singh Psychology, I will ensure that all RAs know how to handle sensitive data with care, maintain confidentiality of the data, use secure procedures for handling and storing the data, and conduct research in an ethical way.

All unpaid/volunteer RAs sign a Business Associate Agreement before they begin their work at Singh Psychology unless the Director of Research deems that this is not necessary given the nature of the research.

Costs of Research

Singh Psychology will only engage in research that it is able and willing to support financially, either through its own funds or through grants and contracts with outside organizations.

Collaboration

If I conduct research with collaborators that involves data collected from my clients, trainees, or students, only the minimum necessary identifying information about my research participants will be provided to the collaborators. I will ask collaborators with whom I share data collected from my clients, trainees, or students to sign a written agreement that includes the certification that the collaborator will make no attempt to reidentify the data, if applicable, and will not share the data with anyone.

Security of Research Data

I agree to adhere to the following minimal standards to store and handle my research data in a secure way that protects the data and protects participants’ privacy. As standards and technology are constantly changing, I will seek ongoing consultation to ensure my standards and processes are up to date.

• Where possible, information that is unique to a participant and would identify that person is removed from the dataset or replaced. For example, each participants’ name may be replaced with a unique research identification number or code;

• Names and social security numbers are not incorporated into or used for ID codes;

• Face sheets containing PII or PHI are removed from completed survey instruments;

• Access to master code lists or key codes is limited to the Director of Research, the Project’s Principal Investigator, and/or other designees approved by the Director of Research or the project’s Principal Investigator.

• Master lists are stored separately from the data and destroyed as soon as reasonably possible (and as indicated in approved IRB protocols).

• Contact lists, recruitment records, or other research documents that contain PII or PHI are destroyed when no longer required for the research.

• Files containing data are not transferred to collaborators (or anyone) via e-mail; instead we will use a secure web-storage service or other means of communication (i.e., telephone).

• Research data/specimens are stored securely in locked cabinets and rooms.

• Electronic data are stored in password-protected computers or files.

• When data are gathered and/or are stored in cloud-based storage locations, the sites meet minimal standards HIPAA standards for security.

• Files containing electronic data are closed when computers are left unattended.

• Consent forms are stored securely in locked cabinets and rooms (or electronically on HIPAA-secure server systems), separately from the research data.

• When using SurveyMonkey or a similar survey tool, the program is set to not collect IP addresses of research participants.

Security Breaches, Protocol Violations, and Other Adverse Events

If a security breach or protocol violation or similar event occurs (e.g., confidential information is shared with someone who should not have access to it; data are lost; etc.), the project’s Principal Investigator (PI) will share information about the situation with the Director of Research and others who are responsible for the research (e.g., other collaborators, IRB chair). In addition to actions required by the specific research’s protocol or the IRB of record, the PI in collaboration with the Director of Research will follow the U.S. Department of Health and Human Services’ Breach Notification Requirements (https://www.hhs.gov/hipaa/for-professionals/breach-notification/index.html). The PI and Director of Research will seek out consultation as needed from qualified persons.

Immediate measures to prevent further or potential harm (e.g., securing a database found to be vulnerable) will be taken in collaboration with the Director of Research.

*Research Policies Last updated 11.03.2023