Integrity in Research Administrative Guidelines | Research

Established: July 2013

Last Updated: July 2024

These Guidelines apply to University of Waterloo staff members, graduate and undergraduate students, post-doctoral fellows, and to anyone else not covered by the Memorandum of Agreement between the Faculty Association of the University of Waterloo and the University of Waterloo (Article 14, Integrity in Scholarly Research) who participates in research activities under the auspices of the University. Such individuals are referred to as UW Person(s).

These Guidelines are written to be consistent with the requirements of the Canadian Institutes of Health Research, the Natural Sciences and Engineering Research Council, and the Social Sciences and Humanities Research Council as outlined in the Tri-Agency Framework: Responsible Conduct of Research (2021). They are also consistent with the UW/FAUW Memorandum of Agreement (Article 14).

Preliminary Matters
1. The University is committed to promoting ethical practices in scholarly research. These Guidelines define what actions do and do not constitute research misconduct, specify research record keeping obligations, and set out the procedures to be followed when the university receives an allegation of research misconduct by a UW Person.
2. The University community recognizes that the responsible conduct of research (RCR) includes:
  1. providing accurate and reliable information in support of funding requests;
  2. responsible use of research funds in accordance with funding agreements;
  3. promoting and protecting the quality, accuracy and reliability of research; and
  4. ensuring that the process for addressing allegations of policy breaches is followed.
3. The Vice-President Research and International (VPRI), is designated as the University's central point of contact to receive any confidential enquiries, allegations of breaches of policies and information related to allegations of misconduct in scholarly research. The Associate Vice President Research Oversight and Analysis is the VPRI’s designate.
4. In these Guidelines “Agencies” means the Canadian Institutes of Health Research, the Natural Sciences and Engineering Research Council and the Social Sciences and Humanities Research Council, “Agency” means one of those funding agencies, and “SRCR” means the Tri-Agency Secretariat on Responsible Conduct of Research.
5. In all matters under these Guidelines, a responding UW Person has the right to be accompanied by a colleague for advice and support (including, if necessary, aid in presenting the UW Person's position) during any meetings attended to discuss such matters.
6. The University shall, where practicable, take disciplinary action against employees or students who make unfounded allegations of misconduct in research which are reckless, malicious, or not in good faith.
Misconduct in Research
1. Factors intrinsic to the process of scholarly research such as honest error, conflicting data, or differences in interpretation or assessment of data or of experimental design do not constitute either misconduct or a lack of integrity.
2. Misconduct in research may include, but is not limited to, one or more of the following:
  1. Fabrication: Making up data, source material, methodologies or findings, including graphs and images.
  2. Falsification: Manipulating, changing, or omitting data, source material, methodologies or findings, including graphs and images, without appropriate acknowledgement, such that the research record is not accurately represented.
  3. Destruction of research data or records: The destruction of one’s own or another’s research data or records or in contravention of the applicable funding agreement, institutional policy and/or laws, regulations and professional or disciplinary standards. This also includes the destruction of data or records to avoid the detection of wrongdoing.
  4. Plagiarism: Presenting and using another’s published or unpublished work, including theories, concepts, data, source material, methodologies or findings, including graphs and images, as one’s own, without appropriate referencing and, if required, without permission.
  5. Redundant publication or self-plagiarism: The re-publication of one’s own previously published work or part thereof, or data, in the same or another language, without adequate acknowledgment of the source, or justification.
  6. Invalid authorship: Inaccurate attribution of authorship, including attribution of authorship to persons other than those who have contributed sufficiently to take responsibility for the intellectual content, or agreeing to be listed as author to a publication for which one made little or no material contribution.
  7. Inadequate acknowledgement: Failure to appropriately recognize contributions of others in a manner consistent with their respective contributions and authorship policies of relevant publications.
  8. Mismanagement of Conflict of Interest: Failure to appropriately manage any real, potential or perceived conflict of interest, in accordance with the Institution’s policy on conflict of interest in research, preventing one or more of the objectives set out in section 1.2 of these Guidelines from being met.
  9. Providing incomplete, inaccurate or false information in a grant or award application or related document, such as a letter of support or a progress report.
  10. Applying for and/or holding an Agency award when deemed ineligible by NSERC, SSHRC, CIHR or any other research or research funding organization world-wide for reasons of breach of responsible conduct of research policies such as ethics, integrity or financial management policies.
  11. Listing of co-applicants, collaborators or partners without their agreement.
  12. Using grant or award funds for purposes inconsistent with the policies of the funding agency; misappropriating grants and award funds; contravening financial policies of the funding agency or University; or providing incomplete, inaccurate or false information on documentation for expenditures from grant or award accounts.
  13. Failing to meet Agency policy requirements or, to comply with relevant policies, laws or regulations, for the conduct of certain types of research activities; failing to obtain appropriate approvals, permits or certifications before conducting these activities.
  14. Failing to comply with Policy 69, Conflict of Interest: (a researcher failing to reveal to the University any significant financial interest he/she has in a company that contracts with the University to undertake research (particularly research involving the company's products or those of its direct competitors) or to provide research-related materials or services. Significant financial interest includes ownership, substantial stock holding, a directorship, significant honoraria or consulting fees but does not include routine stock holding in a large publicly traded company.
  15. Failing to obtain the permission of the author before making significant use in any publication of new information, concepts or data obtained through access to manuscripts or grant applications during the peer review process.
    
    Source: Tri Agency Framework: Responsible Conduct of Research (2021)
Retention of Research Records
1. For the purposes of these Guidelines the term Research Records refers to any data, document, computer file, or any other written or non-written account or object that reasonably may be expected to provide evidence or information regarding the proposed, conducted or reported research that constitutes the subject of an allegation of scientific misconduct. A Research Record includes, but is not limited to, grant or contract applications, whether funded or unfunded; grant or contract progress and other reports; laboratory notebooks; notes; correspondence; videos; photographs; X-ray film; slides; biological materials; computer files and printouts; manuscripts and publications; equipment use logs; laboratory procurement records; animal facility records; human and animal research protocols; consent forms; medical charts; and client research files.
2. UW Persons shall only be responsible for providing access to Research Records which are in their possession and not for Research Records which may be stored in archives, libraries or other institutions which the University may consult at its expense and according to the rules of the host institution. Ownership of such records is governed by Policy 73, Intellectual Property Rights.
3. Normally, for the purposes described in 3.2, UW Persons shall retain Research Records that are within their personal control for the length of time specified in the relevant university records retention schedule where applicable. If there is no applicable University records retention schedule, UW Persons shall retain Research Records for as long as may be reasonable, but in any case for no less a time than is required by the relevant professional association or discipline. UW Persons shall be indemnified by the University for any material loss relating to their Research Records in the course of any investigation, inquiry, or arbitration.
Procedures
1. If the allegation relates to conduct that occurred at another institution, the institution that receives the allegation will contact the other institution and together determine with that institution’s designated point of contact which institution is best placed to conduct the Inquiry and Investigation, if warranted. Negotiations will be made prior to the commencement of inquiry or investigation, ensuring principles of fairness, trust, accountability, and openness between the two institutions. The institution that received the allegation must communicate to the complainant which institution will be the point of contact for the allegation. The UW Person will be made aware of the Institution that serves as the point of contact for the allegation and shall have an opportunity to make a submission on this proposed process. An external institution conducting an Inquiry or Investigation must provide the report to the University’s Vice-President, Research and International.
2. If circumstances warrant, timelines may be extended with the prior written approval of the Vice-President, Research and International.
3. Any oral or anonymous allegation of misconduct in research by a UW Person received by a Chair, Dean, Vice-President or other administrative officer of the University is to be forwarded to the Vice-President, Research and International. Anonymous allegations will be considered if accompanied by sufficient information to enable the assessment of the allegation and the credibility of the facts and evidence on which the allegation is based, without the need for further information from the complainant.
4. 1. An allegation of misconduct in scholarly research shall be submitted in writing to the VPRI or designate who is to determine through an Inquiry whether the allegation may have substance and whether an investigation is to be undertaken. The inquiry may take up to 90 days.
  2. The VPRI may choose to notify the subject of the allegation (the “Responding UW Person”) in writing of the nature of the allegation and that they are to retain all materials relevant to the allegation and invite the Responding UW Person to respond by meeting with him/her or designate and/or submitting a written response. Any such meeting or submission shall take place within ten working days of the notification.
  3. In exceptional circumstances, the institution may independently, or at the request of the Tri-Agency or other funders, take immediate action to protect the administration of Agency or other funds. Immediate actions could include freezing grant accounts, requiring a second authorized signature from an institutional representative on all expenses charged to the researcher’s grant accounts, or other measures, as appropriate.
  4. The VPRI shall determine whether:
    1. there is sufficient evidence to merit a full investigation; or
    2. there is insufficient evidence to merit a full investigation and any material collected is to be destroyed.
      
      The complainant shall be informed in writing of the decision as shall the Responding UW Person if s/he was notified under 4.4.2. In the event that it is determined that there shall be no investigation, the VPRI must inform each individual to whom concerns and allegations were disclosed that there is no basis for an investigation. This will be done within 90 days of receipt of the RCR Allegation Submission Form.
5. If a full investigation is determined appropriate and the Responding UW Person was not notified of the allegation, the Vice-President, Research and International shall notify the Responding UW Person in writing of the nature of the allegation and that s/he is to retain all materials relevant to the allegation.
  
  If the Responding UW Person admits the breach, the Vice-President, University Research may choose to forgo establishing an Investigation Committee and instead report the matter to the UW Person’s relevant associate dean (for students) or supervisor (for others) as discussed in 4.8.
6. The VPRI shall establish a three-person Investigation Committee, comprised of two internal members and one external member who has no current affiliation with the University. Members of the Investigation Committee will be selected so that the Committee has appropriate expertise. Committee members shall not have had any prior connection with the particular matter nor have had a close professional or personal relationship with the Responding UW Person. No person consulted by the University concerning the case shall be appointed.
  
  The Responding UW Person may propose three possible internal Investigation Committee members and three possible external members in accordance with the above criteria. The VPRI will consider any names put forward by the Responding UW Person. If the VPRI is considering appointing someone not put forward, the Responding UW Person shall be given an opportunity to challenge in writing the names proposed by the other with respect to the criteria or for bias, apprehension of bias or perceived conflict of interest. The VPRI shall determine any challenge. Upon establishing the Investigation Committee, the VPRI shall name one of the members as the Committee Chair.
7. The Investigation Committee is to determine whether, on a balance of probabilities, the Responding UW Person committed an act of research misconduct. It shall conduct its proceedings in accordance with the principles of natural justice. It will review the allegation and any material submitted, may obtain additional material (and will provide any such material to the Responding UW Person), will give the complainant and the Responding UW Person an opportunity to appear before it to provide evidence, and may call witnesses to provide evidence.
  
  Upon completion of the evidence gathering, the Committee will provide a report of the relevant facts to both the complainant and the Responding UW Person. Both will have ten working days to submit a written response if s/he chooses to do so.
  
  After the expiry of the ten working days the Investigation Committee shall decide by majority vote on the basis of the evidence submitted to it whether misconduct occurred. Any finding of misconduct in research shall be based only on clear, compelling, written, and documented evidence.
  
  The Chair of the Investigation Committee shall submit a report to the VPRI and the Responding UW Person within seven months of the date on which the allegation was received by the VPRI. The report shall set out, at a minimum, the specific allegation(s), the Responding UW Person’s response, a summary of the finding(s) and reasons for the finding(s).
  
  The report of the Investigation Committee will be maintained in a confidential and secure manner, with limited access, in the office of the VPRI.
  
  The decision of the Committee is final and binding on the Responding UW Person and the University unless successfully appealed under the applicable university policy or procedure.
8. Within ten working days of receipt of a report that misconduct was determined to have occurred, the VPRI will provide a copy of the report:
  1. In the case of a student, to the appropriate associate dean who will make a decision as to what discipline or other action, if any, is appropriate and will send a copy of the report and communicate that decision in writing to the student and the VPRI . Normally such a decision will be made within one month of receipt of the Investigation Committee’s report.
    
    In the case of any other UW Person, to that person’s supervisor who will make a decision as to what discipline or other action, if any, is appropriate and will send a copy of the report and communicate that decision in writing to the UW Person and the VPRI. Normally such a decision will be made within 30 days of receipt of the Investigation Committee’s report.
Reporting
1. Subject to any applicable privacy laws, if an allegation involves significant financial, health and safety or other risks, the VPRI will immediately notify the Secretariat on Responsible Conduct of Research (SRCR).
2. If an allegation concerns an activity about which the SRCR was notified, the VPRI shall, within 60 days of receipt of the allegation, advise the SRCR whether or not an investigation is being undertaken. Timelines may be extended in consultation with the SRCR if circumstances warrant, with periodic updates provided to the SRCR and the UW Person under the inquiry, until the inquiry or investigation is complete.
3. If an investigation is undertaken in response to an allegation of policy breaches related to a funding application submitted to an Agency or to an activity funded by an Agency, within seven months of receipt of the allegation, the VPRI shall submit to the SRCR a report including the following information:
  1. The specific allegation(s), a summary of the finding(s) and reasons for the finding(s);
  2. The process and timelines followed;
  3. The researcher’s response to the allegation, investigation and findings and any measures the research has taken to rectify the breach;
  4. The Investigation Committee’s decision and any recommendations for rectification; and
  5. Actions taken by the University.
4. The report submitted under 5.3 shall not include:
  1. information that is not related specifically to Agency funding and policies; or
  2. personal information about the Responding UW Person or any other person that is not material to the University’s findings and its report to the SRCR.
5. Neither the University nor a UW Person may enter into confidentiality agreements that prevent the University from reporting to the Agencies.
6. If the Investigation Committee sustains an accusation of misconduct in research, and if that research is funded by an outside agency or has been published or submitted for publication, the VPRI shall, inform the agency or publisher concerned and the Responding UW Person of the outcome of the investigation. The VPRI will advise the complainant of the outcome of the investigation, subject to applicable laws, including privacy laws within five working days of receipt of the final report from the Investigation Committee.
General
1. The University shall take such steps as may be necessary and reasonable to:
  1. not make public or allow to be made public by its officers, employees or other persons within its control any reference to the case;
  2. protect the reputation and credibility of UW Persons subjected to an unfounded allegation (whereby the Inquiry found no research misconduct) of misconduct in research, including written notification of the decision to all agencies, publishers, or individuals who were informed by the University of the investigation;
  3. protect the rights, position, and reputation of any UW Person or faculty member who, in good faith, makes an allegation of research misconduct, or whom it calls as a witness in an investigation, including the provision of legal counsel and the payment of other reasonable legal and related costs should the UW Person be sued for her/his participation in any such investigation or arbitration proceedings;
  4. minimize disruption to the scholarly activities of the UW Person or faculty member making the allegation and of any third party whose research may be affected by the securing of evidence relevant to the allegation during the course of the investigation; and
  5. ensure that any disruption in research, teaching, community service and work activities resulting from allegations of misconduct in research does not adversely affect future decisions concerning the careers of those referenced in 6.1.2, 6.1.3, and 6.1.5 above.