I'm not sure to know all details. My guess is that if a non-clinical study is to be conducted on human ( or patient) cells/tissues/samples there should be a protocol and then the protocol should be approved by the EC. The same apply to research on sensitive personal data. If you browse ClinicalTrials.gov you can see many non-interventional studies registered ww. One notable exception may be the case of human samples coming from routine diagnostic procedures in which sampling is primarily not done for the in-vitro testing. However this seems to me a borderline situation and I would recommend to have a protocol approved anyway.
Some additional information below.
Article Ethics Committees in India: Past, present and future