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Yes, that is certainly the best choice.
Even though the subjects may not know that they are participating, this is a human subjects research project, and must therefore be reviewed by an Administrative Panel.
The act of observing or photographing individuals does not, in itself, require Panel review, but, as this is a dissertation project, with the intention of producing generalizable results, it is human subjects research, and therefore requires approval.
The nature of this study may allow for either an expedited or exempt review, depending on the details of the metholology. The Panel may be able to assist in developing a research design to minimize human subjects concerns while assuring a quality project.
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