Why you must apply for ethical approval
Ethical approval is needed for any research that involves human participants; their tissue and /or data to ensure that the dignity, rights, safety and well-being of all participants are the primary consideration of the research project.
Full approval is a mandatory requirement of the College for all research it sponsors and must be sought before the start of the research project. Conducting research without such approval constitutes misconduct. The College takes no responsibility, financial or otherwise for this.
Committee cannot grant approval retrospectively. Only data collected after ethical approval has been given can be used. Any data collected before this must not be used.
Analysis of secondary data requires ethical approval; whether the data is sensitive, anonymised or publicly available.
Unless you can demonstrate that your project is not research you should apply for ethical approval.