It’s definitely not a bright line, which is why you’re supposed to talk to the IRB. In your example, I think it depends on the audience and goal. If you’re usi

It’s definitely not a bright line, which is why you’re supposed to talk to the IRB. In your example, I think it depends on the audience and goal. If you’re using these data to plan a computer lab upgrade, it seems very clearly operational. If you wanted to publish a study entitled “Factors affecting IT utilization at an R1 university”, you probably need to run it by the IRB. In that case, they will almost certainly give you the go-ahead after reminding you not to include any identifiable information.