Your research may not involve human subjects as defined by the Common Rule. However, HIPAA privacy rules may still apply if your research involves PHI from a covered entity even if the subjects are deceased. You will need to consult one or more IRBs and/or privacy boards to review and confirm this. Contact your institution's IRB and/or privacy board and the IRBs and/or privacy boards of other institutions involved in your research, including funding entities, to determine what steps are required to obtain this review and confirmation.