Do I need to include my research staff or student researchers on the protocol?

Anyone who has direct contact with subjects and/or access to subjects’ identifiable data in the context of research must be listed on the protocol with the following exception for staff personnel: if the individual's role on the project is part of his or her regular paid duties (i.e. phlebotomist, x-ray technician) and involvement in the project is limited to performing those duties without contributing to the research endeavor, then such individuals need not be listed as sub-investigators or research personnel.