ARCHIVED – Addressing Allegations of Non-Compliance with Tri-Agency Policies

This information has been archived. Visit the Responsible Conduct of Research page for current information.

Frequently Asked Questions

The following set of Frequently Asked Questions serves as a companion document to the Tri-Agency Process for Addressing Allegations of Non-Compliance with Tri-Agency Policies and related Tri-Agency policy documents.

1) How do I submit an allegation of non-compliance with Tri-Agency policies?
Allegation(s) of non-compliance with Tri-Agency policies must be made directly to the institution employing the individual suspected of non-compliance, with an exact copy of the allegation(s) sent to the relevant Agency. Once the Agency is in receipt of the allegation, the Agency will ensure that the request falls within its mandate, inform the relevant institution that it is aware of the allegation and request that the institution follow up on the concerns raised and report back its finding(s) to the Agency.

Questions on how to submit allegations of non-compliance with research policies should be directed to the relevant Agency, through its designated Agency representative. The contact information for each Agency can be found at the bottom of this page.

Questions on how to submit allegations of non-compliance to institutions should be directed to Office of the VP Research at the relevant institution.

2) Do I have to provide the Agencies with my name when making an allegation or can it be anonymous?
Anonymous allegations sent directly to the Agency will be forwarded to the appropriate institution for follow-up, to the extent possible. It is important to note that anonymous allegations can be difficult to address. Facts that are not publicly available or otherwise independently verifiable may limit an institution’s ability to carry out a thorough and fair investigation.

3) Am I protected if I come forward with an allegation?
Complainants who make allegations in good faith are protected from reprisals according to their institution’s policies and, in some cases, to the extent of applicable laws.

An allegation made in bad faith (i.e. maliciously or in the knowledge that the allegation is without foundation) may itself be a breach and subject to an institutional investigation, depending on the institution’s policy.

4) What happens if the allegations are related to possible criminal misconduct?
Any evidence of possible fraud or criminal activity is reported to the appropriate legal authority. In these situations, the Agencies will carry out the process outlined below, in parallel with the legal authority's activities and agreement.

5) Who investigates allegations of non-compliance with Tri-Agency policies?
In instances where an investigation is warranted, the institution employing the individual suspected of non-compliance is responsible for conducting the investigation, in accordance with its own institutional policies and Tri-Agency requirements, and for communicating its findings to the Agency.

The Agencies do not investigate allegations of non-compliance with Tri-Agency policies, as the Agencies do not have the legislative mandates to do so. When an Agency becomes aware of an alleged breach of Tri-Agency policy, such as a breach of ethics, plagiarism, or misuse of grant funds, it follows the process outlined in the Tri-Agency Process for Addressing Allegations of Non-Compliance with Tri-Agency Policies, to address the allegation and, if necessary, to take appropriate action.

6) If I am under investigation, can I still apply to the Agencies for funding?
Respondents under investigation by an institution can still apply for funding if they continue to meet all eligibility and program requirements. The same applies to funding already approved; however, the Agency may make any grant, award or installment conditional on a finding of no misconduct.

7) How long does it take to resolve an allegation?
As noted in question 5, the institution is responsible for conducting the investigation. That process may be subject to timelines established in the institutional policy but in general, can take anywhere from 30 days to two years or more, depending on the complexity of the issues raised. In cases where the Agency was notified of an allegation, it will follow up with the institution on a regular basis to obtain updates on the status of the investigation and to monitor adherence to the timelines stated in its institutional policy.

For details on Agency timelines, please see the Tri-Agency Decision Tree.

For questions related to specific institutional policies and their timelines, please contact the institution’s Research Office.

8) If the institution's investigation confirms a finding of misconduct, what will happen?
Each institution funded by CIHR, NSERC, or SSHRC has an institutional research integrity policy that must be followed when conducting investigations into allegations of non-compliance. Please consult the institution’s integrity policy for details on the process and possible actions at its disposal.

From an Agency perspective, following receipt of the institution's report, if there is a finding of misconduct, the matter is brought to the Agency’s Integrity Committee for consideration. The Committee may recommend that the Agency take the following types of actions:

• letter of reprimand;
• declaring a researcher / grantee ineligible from applying for future funding for a defined time period or indefinitely;
• terminating remaining installments of the grant or award;
• seeking a refund of all or part of the funds already paid as a grant or award for the research or scholarship involved within a defined time frame;
• ineligibility to serve on agency committees (e.g. peer review, advisory boards).

The respondent will be provided with an opportunity to respond to the Agency’s recommended action(s). It is important to note that the Agencies are not an avenue of appeal regarding findings, decisions or actions taken by the institution. Should a respondent disagree with an institution’s conclusion or finding, they are encouraged to consider the appeal process outlined in their institution’s integrity policy.

The file, including the institution's report, the Agency integrity committee’s recommendation(s) and the respondent’s response will be presented to the Agency’s Senior Management for final decision. If no response from the respondent is received, the matter proceeds to the Agency’s Senior Management for final decision. The decision is communicated to the researcher, his/her institution and is implemented by the Agency.

9) What if I do not agree with the institution’s process and/or its findings?
Should a respondent disagree with the institution’s process and/or findings, the matter should be addressed with the institution during the investigation process or at the time of appeal. The Agencies are not an avenue of appeal regarding institutional findings, decisions or actions taken.

10) What if I do not agree with the actions being considered by the funding Agency?
As noted in question 8, the Agencies’ process includes an opportunity to respond to a notice of actions being considered.

While Senior Management will carefully consider any concerns raised by the respondent about the proposed actions, its subsequent decision is final.

It is important to note that the Agencies are not an avenue of appeal regarding findings, decisions or actions taken by the institution. Should a respondent disagree with an institution’s conclusion or finding, they are encouraged to consider the appeal process outlined in their institution’s integrity policy.

11) Where can I obtain the results of an investigation?
Investigations are administrative matters between researchers and the research institutions that employ them; thus, any queries related to investigations should be directed to the relevant research institution.

The Agencies are prohibited by the Privacy Act from disclosing personal information about identifiable individuals, including information related to investigations. The Agencies do, however, post global statistics ( CIHR, NSERC,  SSHRC) and depersonalized case summaries related to allegations of non-compliance.

12) What happens if my institution is not following its own integrity policy?
Concerns related to an institution not following its own integrity policy can be forwarded to the relevant Agency for review. The Agency will work with the institution to try to resolve the matter as per the terms of Schedule 8 of the MOU. Depending on the degree of severity of the issue, actions such as the following may be taken:

• temporary suspension of funding to specific programs or projects until corrective measures, which the Agency finds satisfactory, are in place;
• in the event that the breach cannot be satisfactorily remedied, the Agency may consider the Institution or all or any portion of its faculty to be ineligible to continue receiving funds from the Agency.

13) How many allegations of non-compliance do the Agencies receive every year?
Global statistics on the number of allegations received by each Agency are available on their respective web sites at:  CIHR, NSERC,  SSHRC.

14) Who do I contact if I have any other questions?
For any questions not answered by the above FAQs, please contact the designated Agency at the coordinates below:

Canadian Institutes of Health Research (CIHR)
160 Elgin Street, 9th Floor
Address Locator 4809A
Ottawa, ON
K1A 0W9
Phone: 613-954-1383
Fax: 613-946-0885
Email: research.integrity@cihr-irsc.gc.ca

Natural Sciences and Engineering Research Council of Canada (NSERC)
350 Albert Street
Ottawa, ON
K1A 1H5
Phone: 613-992-0842
Fax: 613-943-1222
E-mail: sectr@nserc-crsng.gc.ca

Social Sciences and Humanities Research Council of Canada (SSHRC)
350 Albert Street
P.O. Box 1610
Ottawa, ON
K1P 6G4
Phone: 613-992-1058
Fax: 613-996-4824
E-mail: secretariat@sshrc-crsh.gc.ca