ARCHIVED – Framework for Tri-Council Review of Institutional Policies Dealing with Integrity in Research
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Researchers are responsible for adhering to ethical principles in their research activities, and their associated institutions are responsible for monitoring conformity with these principles. The granting councils have in place a number of policies that define the standard of accountability in such areas as research integrity, research involving human and animal subjects, and fiscal responsibility. Institutions are required to show their commitment to the Tri-Council policy statement on Integrity in Research and Scholarship by adopting an institutional policy on integrity in research.
Following an examination of the policies submitted, the three Councils have developed a framework for their review. This framework, outlined below, is based on the general principles, expected process, and other requirements defined in the tri-council document on "Integrity in Research and Scholarship" (see the Tri
Council Policy Statement: Integrity in Research and Scholarship on NSERC's Web site).
To comply with the general principles in the Tri-Council Policy on Integrity in Research and Scholarship and to provide guidance to researchers, the institutions that receive council funding must adopt:
- A general statement of research integrity principles and description of what constitutes misconduct;
- A statement confirming expectations for standards of appropriate behaviour in research for the members of the institutional research community, covering such points as honesty of researchers, respect for others, scholarly competence, and stewardship of resources;
- A statement that both the policy and adjunct policies cover and identify all those involved in the research enterprise in any capacity whatsoever at the institution;
- A policy (policies) on data recording, ownership and retention;
- A policy on authorship and publication (either university-wide or by faculty);
- A policy requiring disclosure of potential conflicts of interest;
- A statement that the institution is committed to ongoing education on research integrity.
Procedures for Processing Allegations
The tri-council integrity policy also stipulates a number of requirements with regard to the process for dealing with breaches of integrity.
Institutional policies must therefore demonstrate that procedures have been established, as required by the Councils, to:
1. Receive allegations of misconduct
- identify a central point of contact, at the vice-presidential level or equivalent (herein referred to Vice-President), to receive allegations within the institution; this will ensure that the individual receiving allegations is sufficiently at arm's length in the administrative structure so as to be viewed as impartial and free of personal conflicts of interest (especially with respect to small administrative units) , and indicates that the institution attaches importance to the issue;
- establish a mechanism whereby administrators who receive allegations must channel them to the vice-president to ensure consistency in dealing with cases;
- policy on anonymous allegations.
2. Conduct inquiries/investigations
- specify the time frame for inquiries and/or investigations, which ensures that such matters receive the highest priority;
- define an appropriate inquiry/investigation process, which would include:
- the appointment process for the committee responsible for conducting the inquiry/investigation;
- a procedure to include appropriate expertise on an investigative committee and to prevent conflicts of interest, real or apparent;
- a procedure to obtain, identify and record documentation to be provided to and kept by the inquiry/investigation panel, and to ensure that all information made available to the inquiry/investigation is included as part of the record(s);
- a procedure to ensure that the inquiry/investigation panel is able to identify and obtain all relevant records;
- a statement of expectations for the format and a timeframe for the transmission of the report to the vice-president.
3. Protect privacy/confidentiality
- identify steps to safeguard, as far as possible, the privacy of the complainant and respondent;
- identify steps to protect the confidentiality of all material/records
pertaining to the investigation.
4. Provide an opportunity for response and for due process
- provide and opportunity for the complainant and respondent to comment on the allegations as part of the investigation;
- provide an opportunity for the inquiry/investigation panel to interview the complainant and respondent;
- ensure that records are maintained of interviews with individuals
5. Make decisions on misconduct
- ensure that the investigative committee reports to the vice-president;
- acknowledge that the investigative committee has the authority to decide on misconduct, and that decision is binding on the institution;
- provide an opportunity for rebuttal if misconduct is concluded.
6. Determine actions in response to a report
- identify a process for recommendations of sanctions, determine appropriateness, and whether to impose them;
- identify a follow-up process, to be developed by the vice-president;
- for unfounded allegations, acknowledge that efforts will be made by the institution to protect or restore the reputation of those unjustly accused, and to ensure that documentation provided to the investigative committees will be destroyed;
- define actions to protect 1) person (s) who have made an allegation in good faith; 2) all persons involved (e.g., witnesses) in an inquiry/investigation.
7. Report on the results of the investigation
- establish a procedure by which the vice-president would inform the parties involved in a timely manner of the decision reached
by the investigative committee and of any sanctions which are to be imposed.
8. Maintain records
- define the time period that reports or records will be kept and by whom, once an inquiry / investigation has been completed
and define access rights within the university to investigative reports or records.
Reporting to Councils
The last section of the tri-council policy deals with information to be provided to the Councils. This must also be addressed in the institutional policies and should include:
- where misconduct was found to have occurred, a commitment, after completion of the investigation, to the forwarding of the report within 30 days of the inquiry/investigation to the Council (s) involved for all cases where the research is funded by the Councils;
- a policy to take action which protects the administration of federal funds if appropriate;
- a mechanism for general summary reporting on internal complaints and for forwarding to the Council (s) a comprehensive report of those allegations that result in a misconduct finding which involves their funding;
- in cases where it is the Council which initiates a request for an inquiry/investigation, a mechanism for providing the Council (s), whose funds are involved, with a comprehensive report of the process and findings.
June 24, 1996