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Several undergraduate and graduate students serve as research assistants for my approved protocols. Are they exempt from the education requirement because they are not faculty or staff?

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Several undergraduate and graduate students serve as research assistants for my approved protocols. Are they exempt from the education requirement because they are not faculty or staff?

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Students who have contact with human subjects or access to private information are required to participate in the education program. The intent of the program is to protect the human subjects involved in research, and/or their private information, by educating all individuals who have contact with either the subjects or their confidential information about the ethical conduct of human subjects research.

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