Subject: Policy and Procedures Related to Integrity in Research*
Approved by: Senate
Approval date: 20 January 2010
Effective date: 20 January 2010
Revised: 12 May 2016
Administered by: Provost and Vice-President, Academic & Research
*Throughout this document, wherever the word “research” is used, it shall be understood to refer to research, scholarly, and creative activities
1 — PREAMBLE
The pursuit of knowledge, ideas, and creativity is fundamental to the work of the University. This leads to excellence in teaching, research, publication, and creative output. These activities must be conducted with the highest degree of rigour, honesty, and ethics. The credibility of individual faculty members, researchers, staff, students, and the entire University rests upon this integrity in the pursuit of knowledge, ideas, and creativity.
In order to protect individuals and the University, a policy and procedures are required both to support integrity in research, and to deal with allegations in misconduct in these matters.
This policy and procedures document describes the manner in which integrity and misconduct in research are dealt with at Mount Allison University. This policy aligns with the Tri-Agency Framework: Responsible Conduct of Research, and draws on similar policy and procedures documents at other Canadian universities. The policy incorporates language used in the Tri-Agency Framework specifically as it relates to research. It incorporates specific clauses and statements drawn from Mount Saint Vincent University’s policy on integrity in research and scholarship, Bishop’s University’s Policy on Responsible Conduct of Research, and the University of Manitoba's Policy on the Responsible Conduct of Research.
Policy 5202 does not supersede or replace provisions in the Collective Agreements between Mount Allison University, the Mount Allison Faculty Association, CUPE Local 3433, or CUPE Local 2338.
Other university policies and procedures specifically address the ethical conduct of research involving humans and animals, and financial integrity in the use of research funds. This document is concerned only with research and scholarly integrity, and does not replace other policy statements and procedures pertaining to issues that may overlap with the focus here: research and scholarly integrity.
2 — DEFINITIONS
Administrative Officer: refers to any or all senior administrative appointments including the Deans, the Director of the Ron Joyce Centre for Business Studies, the University Librarian, the Provost and Vice-President, Academic and Research, and the President.
Breach: refers to any conduct, actions or omissions which are deliberate violations of integrity in research.
Committee of Inquiry: refers to the Committee appointed to carry out an investigation and determine whether or not a breach has taken place and can be substantiated; the Committee shall consist of researchers with the necessary expertise and independence to carry out an inquiry under the University’s policy.
Complainant: refers to any individual or group that alleges a member of the Mount Allison community has breached the policy on responsible conduct of research.
Day: refers to a calendar day, unless otherwise indicated.
Disclosure: refers to an allegation or complaint that a breach has been or is likely to have occurred.
Funding Agency (or Agencies): refers to any agency or organization that provides grants and/or contracts in support of research, including Canada's three federal granting agencies (the Canadian Institutes of Health Research, the Natural Sciences and Engineering Research Council, and the Social Sciences and Humanities Research Council.)
Investigation: refers to an investigation of an alleged breach.
Research: refers to research, scholarly and creative works, whether funded or not, and regardless of where that research takes place; research constitutes the systematic investigation of phenomena, the purpose of which is to discover, create or extend knowledge; included in research its dissemination. The routine development of teaching materials is not considered research, nor is administrative work considered research. (This policy does not apply to research conducted as part of student course work. Research
misconduct on the part of students shall be addressed in accordance with the University's policies on student discipline; see Policies and Procedures for Student Governance.)
Researcher: refers to any member of the Mount Allison University community, including faculty members (full- and part-time), professors emeritae/emeriti, adjunct appointees, visiting researchers, post-doctoral fellows, research associates, research assistants, laboratory assistants, students (undergraduate or graduate), or any other person in a similar position who is involved in research.
Respondent: refers to any individual accused of a breach.
3 — PRINCIPLES OF PRACTICE AND THE RESPONSIBILITIES OF RESEARCHERS
Mount Allison University is committed to the highest standards in research and expects that all persons involved in research shall be guided by integrity. Integrity in research simply means being honest and rigorous in the pursuit of new knowledge and creative expression while adhering to the specific policies, regulations, procedures, and laws applicable. The primary responsibility for research integrity rests with individuals carrying out these activities. Researchers shall be guided by the following principles:
- a. Scholarly competence and intellectual honesty;
- b. Rigour in the development and execution of all phases of research;
- c. Appropriate recognition of the contributors to research including, as appropriate, authorship credit or formal acknowledgement;
- d. Adherence to ethical standards when conducting research involving humans or animals;
- e. Adherence to University policies related to the management of research resources (i.e.,financial, computer, and other administrative policies);
- f. Appropriate citation of the works of others, whether or not those works are published;
- g. Respect of the rights related to intellectual property;
- h. Avoidance of any real, perceived or potential conflict of interest, and disclosure of same to sponsors, post-secondary institutions, journals or funding agency (this shall apply in matters that include, but are not limited to, the review of manuscripts or applications, the testing of products, and carrying out work sponsored by outside sources).
It is understood that these principles shall guide all aspects of research, including but not limited to the conduct of research, the publication of original work, artistic creations, performance in the arts or in professional areas and other activities.
4 — THE RESPONSIBILITIES OF THE UNIVERSITY
Mount Allison University, through the office of the Provost and Vice-President, Academic and Research, is responsible to ensure compliance with the Tri-Agency Framework: Responsible Conduct of Research. The University undertakes to ensure that all researchers are informed about the policies and procedures related to the responsible conduct of research. Specifically, Mount Allison University will provide an environment conducive to the best research practices, where researchers act honestly, accountably, openly, and fairly in the search for, and dissemination of, knowledge.
Mount Allison University will not tolerate any intentional breaches of policy in the conduct of research or its dissemination, and the University will take all necessary measures to promote and maintain research integrity. Where breaches of the policy are alleged to have occurred, the University has an obligation to determine as expeditiously as possible whether or not a breach has occurred, and the severity of the breach. The University shall apply and enforce this policy while guided by the following principles:
a. academic freedom in research, publication, and creative practice is fundamental to the work of the University, and is important for the common good of society;
b. effective procedures that ensure fairness to those whose integrity is brought into question shall be used; this includes giving a researcher a full opportunity to respond to the allegations in accordance with the principles of due process and natural justice; strict confidentiality for a person alleged to be guilty of a breach in order to minimize the potential damage that can be done if allegations are ultimately not substantiated; and
c. those who make an allegation of misconduct and those who may be involved in the investigation of an allegation that a breach has occurred shall be protected by the University; this involves assurances of confidentiality and an institutional commitment to prevent retaliation against those persons.
5 — BREACHES OF RESEARCH POLICY
In accordance with the Tri-Agency Framework: Responsible Conduct of Research, a breach of policy involves a conscious and deliberate act of deception. Such breaches may include, but are not limited to, the following: (Breaches listed in 1-8 are extracted directly from Section 3.1.1 of the Tri-Agency Framework.)
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 acknowledgement and which results in inaccurate findings or conclusions.
3. Destruction of research records: The destruction of one's own or another's research data or records to specifically avoid the detection of wrongdoing or in contravention of the applicable funding agreement, institutional policy and/or laws, regulations and professional or disciplinary standards.*
*This shall also include refusal to provide access to the data that resulted in a published document (without good and sufficient reason), for the purpose of verification by bona fide researchers for the period of five (5) years from the date of publication unless disciplinary conventions of the researcher necessitate a period longer than five (5) years.
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 publications: 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. This shall include, but is not limited to:
- a. the review of research grant applications or manuscripts, and improper reviewing of a research grant application of another researcher;
- b. failure to reveal any material conflict of interest to the sponsors, the University, or to those who commission work, including the testing of products for sale or distribution to the public; and/or
- c. failure to reveal to the University any material financial interest* in a company, organization, partnership or person that contracts with the University to undertake research, particularly research involving the company's products, or to provide research-related materials or services.
*Material financial interest means ownership, stock holdings, a directorship, significant honoraria or consulting or other fees or payments, but does not include minor stock holdings in publicly traded corporations. Such financial interest may be held or received personally or by any member of the individual’s family.
Breaches shall be deemed to have occurred also when a researcher:
9. Fails to comply with applicable federal or provincial statutes, regulations, or guidelines and policies of funding agencies or the University for the protection of researchers, human subjects, or the health and safety of the public, or for the welfare of laboratory animals; or failure to meet other legal requirements (or generally accepted standards) that relate to the conduct or reporting of research.
10. Disposes of intellectual property outside the University without due benefit to those entitled to some return on the investment in such intellectual property.
11. Intentionally misuses funds designated for research purposes.
6 — EXPLOITATION OF STUDENTS
In addition to the breaches of policy outlined above, researchers (whether they be faculty, staff, or students) have a responsibility to ensure that there will be no exploitation of students. Specific examples of exploitation would be:
- a. Engaging students as research assistants or as research participants where they might reasonably fear that to refuse would be detrimental to their interests;
- b. Failure to give proper recognition to the ideas, work or assistance of individuals or to obtain, where appropriate, prior permission for the work to be done; and/or
- c. Encouraging graduate students to prolong research beyond the point where an acceptable thesis could be submitted, in order solely to further the interests of the faculty member.
7 — PROCEDURES FOR ADDRESSING ALLEGATIONS OF BREACHES OF POLICY
The procedures outlined detail how the University will manage allegations and investigate allegations of breaches of policy. As the Administrative Officer with the responsibility for the policy and procedures related to research integrity, the Provost and Vice-President, Academic and Research shall receive any and all allegations, shall manage all allegations, and shall maintain all files related to allegations and investigations. In the event that the Administrative Officer is unable or unwilling to fulfill their responsibilities under the policy and procedures, they shall request that the President appoint an interim Administrative Officer to manage a particular allegation and/or investigation.
7.1 Making an Allegation
A person may make an allegation and do so in writing. An allegation which has been dated shall contain the following information:
- a. The name and contact information of the person making the allegation;
- b. The description of the alleged breach and the approximate date(s) when the alleged breach occurred; and
- c. The name(s) of the individual(s) suspected in the breach.
No formal actions will be taken in cases where an allegation is made anonymously, is not in writing, or does not include all of the required information.
Although disclosures may be made to any Administrative Officer, the ultimate responsibility for the policy and procedures rests with the Provost and Vice-President, Academic and Research. All disclosures shall be relayed to the Provost and Vice-President, Academic and Research for appropriate action. All allegations will be treated as confidential in order to protect the individual making the allegation from possible reprisals.
An allegation made by an external party (e.g., a journal editor, a funding agency) will be treated formally and in accordance with the procedures outlined in this document.
7.2 Initial Review of an Allegation
As a first step and within 10 days of receiving an allegation in accordance with section 7.1, the Provost and Vice-President, Academic and Research shall undertake to determine if the allegation:
- a. was made in good faith;
- b. is not frivolous or vexatious;
- c. deals with a breach of the policy (outlined in section 5); and
- d. is not a matter being dealt with under another University policy or procedure.
This initial review may involve confidential consultation with appropriate officers at the University (e.g., the chair of the animal care committee, the chair of the research ethics board, staff in Financial Services or the Office of Research Services, etc.).
If the initial review of an allegation leads to a conclusion that no breach has occurred, the Complainant shall be advised of this conclusion and that no further action is to be taken. The individual alleged to have breached the policy (the Respondent) shall also be informed that an allegation was received, the essential nature of the allegation, and the reasons why no further action is to be taken.
If the allegation is not rejected, the Provost and Vice-President, Academic and Research shall follow the procedures outlined in this policy to investigate the matter. The Provost and Vice-President, Academic and Research shall inform the Complainant that the matter will be the subject of the procedures outlined in this policy. The Respondent will also be notified of the allegation, and informed of the process to be undertaken to determine the nature and seriousness of the allegation.
In the event that the allegation relates to research funded by a Tri-Council Agency, and is a serious breach of policy involving financial, health, safety or other risks, the Provost and Vice-President, Academic and Research shall report (in writing) the nature of the allegations to the Secretariat, Panel on Responsible Conduct of Research*, and whether or not an investigation will proceed in accordance with the University's policy and procedures. Normally, such reports shall be made within 30 days after an allegation has been received.
The Provost and Vice-President, Academic and Research may take actions to protect the administration of research funds either by freezing a grant account or requiring oversight of expenses charged to a grant account. Where a breach involving Agency funds is found to have occurred, this shall be communicated to the Secretariat, Panel on Responsible Conduct of Research.
*The Panel on Responsible Conduct of Research is the governance structure established by the three national granting councils. It has responsibilities related to the promotion of the responsible conduct of research. In addition to providing the Tri-Council with advice regarding the Framework on Responsible Conduct of Research, the Secretariat also provides advice to universities thereby ensuring a uniform approach in the handling of any breaches of Tri-Council policies.
7.3 Establishing a Committee of Inquiry
Where the Provost and Vice-President, Academic and Research determines that an investigation is required, in consultation with the Dean of Graduate Studies and the Secretary of Senate they will appoint a Committee of Inquiry consisting of a minimum of three (3) individuals to conduct an investigation. The individuals selected shall have the requisite knowledge and expertise to conduct the investigation, and be without a conflict of interest (real or perceived). The Committee of Inquiry shall include:
- a. at least one (1) individual holding an academic appointment at Mount Allison University; and
- b. at least one (1) individual who has no current employment relationship with Mount Allison University.
The Chair of the Committee of Inquiry shall be designated by the Provost and Vice-President, Academic and Research. If an individual appointed to serve on a Committee of Inquiry is unable or unwilling to fulfill their duties, the Committee may continue its work provided that it has at least three (3) members. If necessary, the Provost and Vice-President, Academic and Research may add a replacement member to a Committee of Inquiry.
7.4 The Investigation Process
The Committee of Inquiry shall decide on its own process for determining whether an allegation can be substantiated and whether such an allegation constitutes a serious breach of the policy. The Committee shall be provided with any documentation known to exist concerning the allegation, and the University will enable the Committee to conduct a fair and thorough investigation. The Committee of Inquiry may also, as appropriate,
- a. interview witnesses in person;
- b. gather information in writing (including by e-mail) from witnesses;
- c. review documents and other relevant exhibits;
- d. examine physical evidence;
- e. arrange for the testing of physical evidence; and/or
- f. request access to electronic systems that may contain relevant evidence. In all cases, the Committee shall consider the credibility and reliability of evidence.
The Complainant shall have an opportunity to explain and provide evidence in support of the allegation. The Respondent, who will have been provided with information on the essential nature of the allegation, shall have an opportunity to respond to the allegation. Any witnesses (including the Complainant and the Respondent) shall be able to consult with an advocate (including legal counsel or a union representative, as may be appropriate).
The Committee shall undertake its investigation within a reasonable period of time. Normally, an investigation shall be completed within 60 days of the allegation being assigned to the Committee. The Committee may seek an extension of its deadline through a request to the Provost and Vice-President, Academic and Research.
In the course of its investigation, should the Committee discover other breaches of the policy and/or the involvement of other individuals in the breach of the policy, the Committee (through the Chair) shall request of the Provost and Vice-President, Academic and Research that the scope of the investigation be enlarged.
7.5 The Report of the Committee of Inquiry
Once the Committee has completed its investigation, it will submit a report of its findings to the Provost and Vice-President, Academic and Research within 10 days. The report shall include the following:
- a. a copy of the allegations;
- b. a summary description of the investigation process;
- c. a written response (if any) of the Respondent(s);
- d. a summary of the key evidence obtained through the investigation, including the response(s) of the individual(s) alleged to have breached the policy;
- e. a statement of the Committee’s findings as to whether or not an allegation has been upheld, and the reasons for the finding;
- f. a summary of any remedial measures taken in regard to the breach; and
- g. recommendations regarding mitigation steps, remedial measures, and due diligence against future breaches.
The report must be supported by a majority of the members of the Committee of Inquiry. If the Committee is unable to reach a majority decision, the Chair shall inform the Provost and Vice-President, Academic and Research, who may constitute a new Committee to initiate a new investigation or abandon the investigation. The Provost and Vice-President, Academic and Research may request that the Chair of the Committee prepare a redacted version of the report in order to protect confidentiality and to protect the identity of persons involved in the investigation. Redactions shall be in accordance with applicable privacy legislation and these procedures.
The report in its entirety (including all documents and materials examined by the Committee of Inquiry) shall be retained by the Provost and Vice-President, Academic and Research for a period of seven (7) years, after which the report in its entirety shall be
The Provost and Vice-President, Academic and Research will provide an appropriate version of the report (either in original or redacted form), within 10 days of the conclusion of the investigation to all persons accused of causing or contributing to a breach of the policy.
The University and the respondent may not enter into confidentiality agreements or other agreements related to an inquiry or an investigation that prevent the University from reporting to the Agencies or to the Secretariat, Panel on Responsible Conduct of Research.
If the Committee of Inquiry concludes that the allegation is not upheld, no reference to the allegation shall be placed in the official file of the Respondent. Where a Committee of Inquiry finds that a researcher has been wrongfully accused of a breach of the policy, the University shall take reasonable steps to restore the individual’s reputation. If an allegation is upheld, a letter of discipline shall be placed in the official file of the Respondent in accordance with the relevant collective agreement.
If the Committee of Inquiry concludes that a breach has occurred, was intentional and not the result of innocent error or oversight, the individual shall have an opportunity to appeal the decision through the Office of the President. Any appeal must be submitted within 30 days of the notice of the Committee’s findings. Appeals may be made on either procedural or substantive grounds. The appellant shall submit in writing the case for appeal, outlining the reasons and evidence to support the appeal. The President shall be provided a copy of the complete report prepared by the Committee of Inquiry as well as the appeal and accompanying documentation. The President shall have the discretion to interview any individuals involved in the case, including members of the Committee of Inquiry and the Provost. Normally within 10 days, the President shall inform the appellant as to whether the appeal is granted or denied.
In cases where an appeal on procedural grounds is granted, the Provost shall refer the case back to the Committee of Inquiry so that the procedural error is corrected. Alternatively, the Provost may decide to establish a new Committee of Inquiry. Whether or not a new Committee of Inquiry is established shall be at the discretion of the Provost, and informed by the nature and severity of the procedural error. In cases where an appeal on substantive grounds is granted, the Provost shall proceed as in the case of an allegation having been rejected.
In cases where an appeal on procedural or substantive grounds is not granted, there shall be no further appeals.
7.7 Reporting on the Outcome of an Investigation
In cases where an individual who was found to have breached the policy does not appeal the Committee’s decision, or if any such appeal is denied, then within 60 days of the Committee's report, the Provost and Vice-President, Academic and Research will provide a summary or an appropriate version of the report (either in original or redacted form) to:
- a. the Complainant;
- b. if relevant, any collaborators of the researcher(s) who are accused of causing or contributing to a breach (including individuals at other institutions);
- c. all such individuals (including individuals at other institutions) who may be involved in deciding upon discipline, mitigation steps, remedial actions, or due diligence to prevent similar or related breaches in the future;
- d. all such individuals who may protect or restore the reputation of those wrongfully accused of causing or contributing to a breach; and
- e. any other person required in order to comply with legal, regulatory, or contractual obligations.
Also within 60 days of the receipt of the Committee’s report on the investigation, the Provost and Vice-President, Academic and Research shall submit a summary of the investigation and any steps to be taken to the Funding Agency (if appropriate) and to the Secretariat, Panel on Responsible Conduct of Research.
The summary shall include:
- a. the specific allegation(s), including the names of any researcher(s) alleged to have breached the policy, a summary of the finding(s) and reasons for the finding(s);
- b. the process and timelines followed for the investigation;
- c. the researcher's response to the allegation, investigation and findings, and any measures the researcher has taken to rectify the breach; and
- d. the Committee's decisions and recommendations and actions taken by Mount Allison University.
In the event that an individual is found to have breached the policy, notice will be provided as follows:
Category of Individual Found to Have Breached the Policy — [Administrative Officer to be Provided Notice of a Breach of the Policy]
- Faculty member or librarian — [Dean of the Faculty or Director, Ron Joyce Centre for Business Studies, or University Librarian]
- Non-academic employee (including post-doctoral fellows) — [Director, Human Resources]
- Graduate Students — [Dean, Faculty of Graduate Studies]
- Undergraduate Students — [Vice-President, International and Student Affairs]
Disciplinary measures may be applied to:
- a. individuals who have breached the policy;
- b. individuals who have made an allegation found to be frivolous or vexatious; and/or
- c. individuals who refuse to co-operate with the Committee of Inquiry.
Any discipline will be implemented pursuant to and in accordance with the relevant collective agreement or University policy. Breaches of the policies and regulations of a Funding Agency may result in additional discipline or penalties imposed by the Funding Agency.
7.9 Informal Resolution
Provided that the breach does not involve a significant financial, health and safety, or other risk, and provided that there are no legal, contractual, or Funding Agency requirements to pursue a formal process, an informal resolution may be sought if and only if both the Complainant and the Respondent agree to pursue such a course of action. An informal resolution may occur prior to or during a formal investigation process. If a formal investigation is underway, the Provost and Vice-President, Academic and Research may pause that process in order that an informal resolution takes place. If an informal resolution is not achieved, the formal process shall proceed in accordance with the procedures outlined in this document.
SUMMARY OF PROCESS
The attached flow-chart outlines the process in connection with breaches of the Policy on Integrity in Research. Below, the timeframe for the process is outlined.
- Within 10 days, an initial assessment of the allegation is made by the Provost.
- If a Committee of Inquiry is established, it shall have 60 days to carry out its investigations.
- The Committee of Inquiry shall submit a report to the Provost within 10 days after the conclusion of its investigations. (Upon receipt of the Committee of Inquiry’s report, the discipline provisions of the collective agreements shall be initiated, as appropriate.)
- Within 10 days of receiving the report of the Committee of Inquiry, the Provost shall provide an appropriate version of the report to the individual accused of causing or contributing to a breach of the policy.
- The individual accused of the breach shall exercise their right to appeal the decision of the Committee of Inquiry within 30 days of the notice of the Committee’s findings.
- The President shall render a decision to grant or deny the appeal within 10 days of receiving the appeal.
- If the individual found to have breached the policy does not appeal, or if the individual’s appeal is denied by the President, the Provost shall, within 60 days of receiving the report of the Committee of Inquiry, report on the findings to the appropriate persons (outlined in the policy) and to the Secretariat, Panel on Responsible Conduct of Research. Cases involving Agency-funded research shall be reported to the Agency.
- If the allegation relates to research funded by a Tri-Council Agency, the Provost shall, within 30 days, report the nature of the allegations to the Secretariat, Panel on Responsible Conduct of Research, and whether or not an investigation will proceed in accordance with the University’s policy and procedures.
In circumstances where discipline is imposed, the timelines shall conform to the provisions of the relevant collective agreement.
A Schematic Representation of the Process for Dealing with Allegations of Breaches of Academic Integrity