I mean tons of retrospective studies are literally "IRB exempt" (and highlighted as such in their methods) where no explicit consent is required or needed. Physicians doing case reviews don't need consent of the patient this work. Doing retrospective analyses for defining clinical phenotypes on patient data that has been aggregated isn't needed either. Collecting clinical MRIs to do deep learning doesn't require an IRB.
IRBs are only REALLY required when you are intervening in patient care or pose some theoretical risk to a human.
Some institutions still want you to submit approval for institutional data, but as a non-lawyer it seems that's much more of a CYA policy.
IRBs are only REALLY required when you are intervening in patient care or pose some theoretical risk to a human.
Some institutions still want you to submit approval for institutional data, but as a non-lawyer it seems that's much more of a CYA policy.