When used exclusively for assessment, management or improvement purposes, the following data collection activities do not require an ethics review, provided there is no intent for the activity to be considered research as outlined by the Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans--TCPS (2022). This includes:
- quality assurance and improvement (QA/QI) projects,
- program evaluation activities,
- performance reviews, or
- testing related to assessing performance of employees or students within normal educational or employment requirements.
This position is consistent with Article 2.5 of the TCPS 2 (2022). These activities are generally administered in the ordinary course of the operation of the organization where participation is required and/or encouraged by employees or students, for example, performance appraisals and student course evaluations.
QA/QI at the University of Waterloo
Although University of Waterloo activities associated with QA/QI may be exempt from an ethics review, it is expected that these projects be conducted responsibly and ethically following the guiding principles of the Tri-Council Policy Statement 2 (2022).
Institutional Analysis and Planning coordinates campus-wide surveys. Faculty, staff, or students who are looking to conduct a QA/QI project are to contact Institutional Analysis and Planning to discuss their project.
Frequently asked questions: Quality assurance or research?
Question: How do I determine whether my data collection activity qualifies as research?
Response: To determine whether a QA/QI activity qualifies as research, it is essential to consider the underlying intent, specific objectives, and how the resulting data may be used. Whether a QA/QI activity constitutes research—and therefore requires an ethics review—must be determined on a case by case basis, taking into account the specific context and characteristics of the activity (TCPS 2 Interpretations, Scope #2). This includes purpose, nature, and intent of the activity rather than its methods alone.
Question: Does the intent to publish—or where the results are shared—determine whether an activity constitutes research?
Response: No. In assessing whether a data collection activity constitutes research or a QA/QI activity, the decision is not dependent on the intention to publish or disseminate the results more broadly. Results may be published in relevant journals (e.g., quality assurance or program evaluation journals) or shared through presentations (e.g., conferences) without altering the original purpose for which the data were collected (TCPS 2 Interpretations, Scope #2).
Question: What is the primary factor in determining whether a QA/QI activity is considered research and therefore requires ethics review?
Response: A QA/QI activity is considered research requiring ethics review only if it seeks to address a research question that extends knowledge beyond the specific program or setting, contributing to knowledge that may be applicable to other programs or contexts (TCPS 2 Interpretations, Scope #7).
Dual-Focus: Research and QA/QI
If the activity, and associated data, is intended to address both a research and non-research purpose, an ethics review will be required. This dual purpose needs to be clearly communicated during the consent process to prospective participants. If the activity is required for QA/QI purposes (e.g., mandated by the employer), it is important to inform participants that their consent to use the data for research purposes is voluntary and distinct from the QA/QI activity. Participants must have the option to decline the use of their data for research purposes, as voluntariness is essential to their participation in research (TCPS 2 Interpretations, Scope, 8). Keep in mind, QA/QI activities conducted solely as part of an organization's regular operations are exempt from an ethics review. When uncertain about whether a data collection activity requires an ethics review, please see ‘Does my data collection activity require ethics review’ and contact Research Ethics if you have questions.
Secondary Use and QA/QI
If data was originally collected for QA/QI purposes and there is an intent to later use it for a research study, this would constitute secondary use of information for research purposes and require an ethics review. In this case, the intended user/recipient of the data (i.e., researchers) would complete a ‘Secondary use of information for research purposes’ application in the research ethics system. Please see Section D of Chapter 5 of the TCPS 2 (2022) for more information on projects involving the secondary use of information for research purposes.
For inquiries related to your data collection activity or research ethics review, please contact Research Ethics.
References
Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans – TCPS 2 (2022). Retrieved June 12, 2025.
Panel on Research Ethics: Policy interpretations: Government of Canada. Retrieved June 18, 2025.
Resources
Does my data collection activity require research ethics review? --University of Waterloo guideline
Updated September 2026