Earlier quoted context omitted.
The key phrase is: > a living individual about whom an investigator (whether professional or student) conducting research: The mere fact that you're interacting with a human doesn't trigger it. If you're associated with a university, I'd encourage you to reach out to your IRB and ask them. The fact that the researchers in this case specifically were told by their IRB that it wasn't human subject research should be a…
This is actually the most technically correct answer on this page. Everyone is going by their own opinions about definitions of what constitutes human subjects research, rather than starting from the primary sources. IRB guidelines are dictated by the federal government "common rule", a common standard adopted by all institutions that receive federal funding. "about whom" is a key criteria from the federal government…
To be a bit more pithy, here is one example of such an analysis (admittedly, I'm not sure comments on twitter count): https://twitter.com/RossTeixeira/status/1471249559879929861