Does Waterloo have a policy and a process for investigating allegations of irresponsible conduct of research which is different from the policy and process used to report and investigate allegations of other types of academic misconduct?
How does the Tri-council definition of “research”, and subsequent interpretations and clarifications of what is or is not “research” posted on their website, apply to the types of activities typically conducted at the University of Waterloo?
As a member of the University of Waterloo community, are my academic integrity and research integrity obligations the same?
Although the general principles which underpin all forms of integrity (i.e., personal, academic, research) are exactly the same (e.g., honesty, trust, fairness, respect, responsibility, transparency, objectivity, lack of conflict of interest), when faced with a potential academic offense situation the first determination which needs to be made is whether the alleged misconduct is irresponsible conduct of research or another type of academic misconduct.
This is an important distinction and a critical first step because irresponsible conduct of research is one special type of academic misconduct which has its own externally imposed reporting and investigation obligations. In other words, all irresponsible conduct of research is academic misconduct but not all academic misconduct is irresponsible conduct of research.
If there is any doubt concerning the classification of the alleged offense, please consult with the Vice President, Research and International.
Does the University of Waterloo have a policy and a process for investigating allegations of irresponsible conduct of research which is different from the policy and process used to report and investigate allegations of other types of academic misconduct?
Yes. If the alleged misconduct is classified as irresponsible conduct of research, it should be immediately reported to the Vice President, Research & International, along with the following information:
- What is the nature of the alleged irresponsible conduct of research (e.g., plagiarism, falsification of data, mismanagement of funds)?
- If this allegation involves published works, include specific citations.
Who raised the issue? Did you receive this in writing? Was it anonymous?
If anonymous, what attempts have been made to determine the identity of the accuser?
If activities have occurred over a period of time, include a timeline or chronology of events.
In what manner was this allegation first brought to your attention (e.g., e-mail, retraction watch, verbal conversation)? When did this occur?
Do you have any concerns regarding the classification of this as irresponsible conduct of research?
Who has been told about the alleged breach so far?
Does it involve any external funding agencies (e.g., Tri-council, National Institutes of Health (NIH), industry sponsor)?
Does it involve any significant financial, health, safety or other risks?
These questions make up a sample irresponsible conduct of research complaint form to help ensure that you have gathered all relevant information.
Irresponsible conduct of research offenses will then be investigated in accordance with university policies governing research integrity and the investigation of irresponsible conduct of research allegations.
If the allegation concerns a faculty member, the irresponsible conduct of research reporting and investigation policy and procedures are contained in Article 14 of the faculty memorandum of agreement “Integrity in Scholarly Research”. However, if the allegation concerns any other member of the University of Waterloo community (e.g., student, staff member, anyone not covered by the faculty agreement), the policy and process is contained in the integrity in research administrative guidelines (PDF) . These processes have now been aligned. They are essentially the same.
If the alleged misconduct is not irresponsible conduct of research, it should be investigated as an academic integrity or other offense using the appropriate policy governing academic offenses (i.e., for students) or processes governing other types of performance issues arising from employment obligations (i.e., for staff, faculty or other members of the Waterloo community).
Why are the processes for investigating academic misconduct and irresponsible conduct of research different?
As a research intensive university, the University of Waterloo needs to ensure that we are in full compliance with obligations imposed by funding sponsors. One of the key sources of research funding in Canada is Tri-Agency funding (i.e., NSERC, SSHRC and CIHR). In December 2011, these three funding agencies imposed a new set of irresponsible conduct of research reporting and investigation obligations on those who wish to receive Tri-Agency funds. This is called the Tri-Agency Framework: Responsible Conduct of Research. Since that date, Waterloo has had to revise its existing agreements, guidelines, policies and processes for reporting irresponsible conduct of research allegations to ensure we are in full compliance with these externally imposed obligations. Institutions which are not in full compliance with this framework are ineligible to receive Tri-Agency funding. Full compliance was achieved in July 2013. It is to be noted that whether the research is Tri-Agency funded or not, the processes and policies to be funded are identical. Having a similar set of processes to investigate all irresponsible conduct of research allegations is a requirement under the Tri-Agency Framework: Responsible Conduct of Research.
There is no single definition of research universally accepted by all funding agencies, institutions and sponsors. However, the Tri-Agency Framework: Responsible Conduct of Research does define research in the following manner:
For the purposes of this guideline, “research” is defined as “an undertaking intended to extend knowledge through a disciplined inquiry or systematic investigation... A determination that research is the intended purpose of the undertaking is key . . .” (Tri-Council Policy Statement 2nd ed., p. 15)
How does the Tri-Council definition of research, and subsequent interpretations and clarifications of what is or is not research posted on their website, apply to the types of activities typically conducted at the University of Waterloo?
Under most circumstances the following activities should be categorized as research:
- Research funded by Tri-Councils (i.e., NSERC, CIHR, SSHRC) or other sponsor grants
- Contract or industrial research
- Research which requires review by the Human or Clinical Research Ethics Board or Animal Care Committee
- Course based research requiring Research Ethics Board (REB) review
- Fourth year theses, Masters theses, PhD dissertations
- Major/Masters research projects
- Post-doctoral research projects
- Faculty research approved by Dean, conducted as part of protected research time (i.e., not necessarily funded)
- Original investigations to apply existing knowledge in a novel way; to produce new products, devices, processes, systems, and services; offer improvements over those already produced or installed (i.e., applied research)
- Research conducted as part of a consulting assignment
If the activity does not fall into one of the categories listed above, a specific determination needs to be made as to whether or not this activity is research. In order to determine if this may be research, please consider the following two questions:
- Is “research” the intended purpose or primary objective of the undertaking?
If the primary objective is purely professional skill development it is probably not research since the primary objective of a professional skill development activity is to demonstrate to the instructor that the student has acquired job or career related skills. This may include skills which will subsequently be used to perform research in the future (e.g., apply statistical research methods/models or conduct a literature review (for academics), conduct market research (for marketers or entrepreneurs), conduct patient interviews (clinicians).
Article 6.12 of TCPS2 states that ethics review is required where the activity or project has “the objective of providing them [i.e., students] with exposure to research methods in their field of study”. Therefore the pedagogical exercise should have as its objective the development of research oriented skills.
If the primary objective is capstone course skill or knowledge demonstration it is probably not research since the primary objective of capstone course reports or activities is not to generate new knowledge but rather to apply existing knowledge derived from classroom learning. The primary objective of capstone courses might be to provide proof of skill acquisition, to facilitate transfer of training or to deepen knowledge acquisition in different contexts (e.g., applying specific processes or models in a consulting engagement with a client, applying clinical techniques in a real world or simulated environment, participating in an internship). In the case of a capstone course, the primary audience is the instructor in order to satisfy academic requirements.
Co-op/work placement reports are typically not research since the primary objective of the report is to summarize the student experience to the coop office or instructor. However, although the coop report itself may not be research, the work undertaken during the course of the co-op or work placement could be research. In many situations this could be a form of applied research. If this research is undertaken at the University of Waterloo, it would fall under the Tri-Agency Framework and university policies. In the case of research undertaken while in the employ of another organization, this would not be a University of Waterloo research integrity violation.
Quality assurance studies, performance reviews or testing related to assessing performance of employees or students within normal educational or employment requirements (and when used exclusively for assessment, management or improvement purposes) are typically not research provided that the study contains no element of research. The specific results of quality assurance studies or performance or program review are generally administered in the ordinary course of the operation of the organization where participation is required by employees or students (e.g., performance appraisals, student course evaluations) and are not generally available for public release outside the institution.
- Does the activity involve a disciplined inquiry which is conducted with the expectation that the method, results, and conclusions will be able to withstand the scrutiny of the relevant research community?
In many situations, research is intended to produce results which are generalizable and/or which generate new knowledge within a discipline using discipline specific methods and approaches. As such, research should have the potential to be disseminated outside the organization via published articles, presentations at seminars and conferences, or uploaded to publicly accessible and searchable databases in the case of theses and dissertations.
Whether you are a student, staff member, faculty member, Chair or Dean, you have both a right and a responsibility to report any instances of irresponsible conduct of research you uncover using the process described in the integrity in research administrative guidelines (PDF) or Article 14 of the faculty memorandum of agreement, whichever applies to the person(s) involved.
However, before reporting the offense, you should ensure that this offense would likely be considered to be irresponsible conduct of research and not another form of academic misconduct or a more general performance issue as described above in questions.
What are the timelines involved? Could I delay reporting this allegation until I first determine if it has merit?
All allegations of irresponsible conduct of research should be immediately reported to the Vice President, Research and International. Under the The Tri-agency Framework: Responsible Conduct of Research institutions have very specific and stringent reporting and investigation timelines to which they must adhere.
In contrast to the more decentralized process previously in place at Waterloo, under the new process there is no preliminary departmental investigation required. Rather, investigations occur using a more centralized process and it is the specific responsibility of the Vice President, Research and International to determine, at a preliminary inquiry stage, if the allegation has any substance and should form the basis for a subsequent investigation by a committee.
Does the University of Waterloo offer any special training or assistance to help me identify possible irresponsible conduct of research and manage situations so these do not occur?
Yes. The University of Waterloo has purchased online training which deals with some of the most common issues likely to form the basis for a irresponsible conduct of research complaint (e.g., misuse of funds, inadequate acknowledgment, data fabrication).
This online training is available at no cost to faculty, staff, and students. It is highly recommended that all Waterloo personnel who will be engaged in conducting research on behalf of the University of Waterloo complete this training.
Principal Investigators (PIs), in particular, would benefit from being able to distance themselves from irresponsible conduct of research allegations levied against members of their team by offering the defense that members of their research teams who may be found guilty of irresponsible conduct of research have completed appropriate training and that the PI has been appropriately diligent in setting clear expectations and managing the skills and competencies of those involved with the research project.
What do I need to include when reporting alleged irresponsible conduct of research to the Vice-President, Research and International?
Although not an exhaustive list, the following items should be included in any formal complaint of irresponsible conduct of research made to the Vice President, University Research and International.
Sample Statement of Complaint of Irresponsible Conduct of Research
- What is the nature of the alleged irresponsible conduct of research offense (e.g., plagiarism, falsification of data, mismanagement of funds)?
- If this allegation involves published works, include specific citations.
- Who raised the issue? Did you receive this in writing? Was it anonymous?
- If anonymous, what attempts have been made to determine the identity of the accuser?
- If activities have occurred over a period of time, include a timeline or chronology of events.
- In what manner was this allegation first brought to your attention (e.g., e-mail, retraction watch, verbal conversation)? When did this occur?
- Do you have any concerns regarding the classification of this as irresponsible conduct of research?
- Who has been told about the alleged breach so far?
- Does it involve any external funding agencies (e.g., Tri-agency, NIH, industry sponsor)?
- Does it involve any significant financial, health, safety or other risks?
If you require further assistance or have any questions concerning Waterloo's guideline or processes to manage allegations of research misconduct, please contact Ian Milligan, Associate Vice-President, Research Oversight and Analysis, 519-888-4567, ext. 42775.