Possibly. And the IRB review process may allow for non disclosure under circumstances of that sort.
The problem is not merely that the IRB allowed non disclosure. It's that the IRB also granted an exemption from full review as human subject research. If the researcher expected that human behavior might change based on secrecy vs. disclosure then it is fundamentally not passive data collection.
But debating the secrecy issue or limits if what constitutes a human subject are all besides the point: the research protocol had an adverse impact on humans involved with the study. Not matter any other considerations, that makes the research defacto one that should have had full IRB review. Evaluating the potential for adverse impact is literally one of the foundational reasons for the existence of IRBs. The presence of an adverse impact is defacto proof that an exemption should not have been granted and that a full review should have been done to determine how the protocols could be tweaked to mitigate the issue.
Possibly. And the IRB review process may allow for non disclosure under circumstances of that sort.
The problem is not merely that the IRB allowed non disclosure. It's that the IRB also granted an exemption from full review as human subject research. If the researcher expected that human behavior might change based on secrecy vs. disclosure then it is fundamentally not passive data collection.
But debating the secrecy issue or limits if what constitutes a human subject are all besides the point: the research protocol had an adverse impact on humans involved with the study. Not matter any other considerations, that makes the research defacto one that should have had full IRB review. Evaluating the potential for adverse impact is literally one of the foundational reasons for the existence of IRBs. The presence of an adverse impact is defacto proof that an exemption should not have been granted and that a full review should have been done to determine how the protocols could be tweaked to mitigate the issue.