Policy on Integrity in Research
Approved by the Faculty Council on January 20, 2022.
Adopted by the Senate on May 12, 2022.
- 1 - PREAMBLE
- 2 - OBJECTIVES
- 3 - SCOPE
- 4 - DEFINITIONS
- 5 - PRINCIPLES
- 6 - PROCEDURE FOR MANAGING CONFLICT OF INTEREST SITUATIONS
- 7 - PROCEDURE FOR PROCESSING ALLEGATIONS OF MISCONDUCT OR BREACH OF INTEGRITY IN RESEARCH
- 8 - SHARING OF RESPONSIBILITIES
- 9 - ADOPTION, IMPLEMENTATION AND DISSEMINATION OF THE POLICY
- 10 - ASSESSMENT OF IMPLEMENTATION AND REVISION OF THE POLICY
1 - PREAMBLE
There are many ethical issues surrounding integrity in research, but public confidence in those involved in research, the research process itself and research results are centralFootnote 1. This policy on integrity in research is situated within this context.
Through this policy, Royal Military College Saint-Jean (RMC Saint-Jean) wishes to foster and promote values of integrity in research. It is also intended to respond to the requirements and expectations of the granting agencies in terms of integrityFootnote 2.
This policy complements the Policy Statement: Ethical Conduct for Research Involving Humans of RMC Saint-Jean.
2 - OBJECTIVES
2.1 Define the main terms associated with integrity in research;
2.2 Specify the principles that guide RMC Saint-Jean in terms of integrity in research;
2.3 Outline the procedure for managing conflict of interest situations and the procedure for processing allegations of misconduct or breach of integrity in research;
2.4 Specify the responsibilities of stakeholders with respect to integrity in research.
3 - SCOPE
This policy applies to all persons doing research at RMC Saint-Jean or on behalf of RMC Saint-Jean, in any capacity.
4 - DEFINITIONS
4.1 The expression integrity in research means all conduct respectful of the dignity of persons and the intrinsic values of scienceFootnote 3.
4.2 Misconduct or breach of integrity in research means [translation] “any intentional or negligent or careless conduct that threatens integrity in research"Footnpte 4 or any form of complicity with respect to such conduct.
Examples of misconduct or breach that could lead to sanctions include, but are not limited to, the following:
- Falsification, distortion, concealment and fabrication of data;
- Absence of details regarding the scope or limit of results;
- Negligence in taking into consideration the state of knowledge on a subject;
- Plagiarism, stealing ideas or appropriating the work of others;
- Use without authorization of confidential information to modify one’s own research or direct it differently;
- Inadequate recognition of the contribution of a co-researcher or any other person who collaborated in the research;
- Failure to respect the confidentiality of information obtained as an evaluator;
- Misrepresentation in an application or related agency document;
- Mismanagement of funds from a grant or scholarship;
- A violation of policies and requirements concerning certain types of research;
- A false or misleading accusation against a person regarding misconduct or breach in integrity in research;
- Failure to follow rules concerning conflict of interest situations.
4.3 A conflict of interest is “any situation in which the interests of an individual subject to this policy conflicts with the individual’s responsibilities and duties. Conflicts of interest can be actual, apparent, or potential. For example, they can be financial, political, ideological, or professional. They can relate to the [institution], to the individual, relatives, friends, or business associates, whether past, present, or future.”Note de bas de page 5
Examples of conflicts of interest that must be declared and could lead to sanctions if they are hidden include, but are not limited to, the following:
- Participating in the assessment of a research project when the person is closely or distantly associated with this project;
- Having a direct or indirect, financial or other, interest, in an external company that is involved or is likely to be involved with RMC Saint-Jean with respect to research;
- Using, for personal benefit or the benefit of a third party, the resources or research of RMC Saint-Jean (time, facilities, premises, equipment, etc.);
- Entering into a contract with an external company in which a person associated with the research has a direct or indirect, financial or other, interest;
- Directing research activities at RMC Saint-Jean in a way that responds to the needs of an external company in which the researcher has a direct or indirect, financial or other, interest;
- Accepting any gift or benefit from an external company that is in a relationship with RMC Saint-Jean;
- Using research funds to serve the specific interests of a grant recipient;
- Using the name of RMC Saint-Jean or its logo for personal purposes;
- Participating in the hiring or promotion, at RMC Saint-Jean with respect to research, of a family member or other persons with whom the person has ties.
5 - PRINCIPLES
Regarding integrity in research, RMC Saint-Jean recognizes the following principles:
5.1 Respect for collaborators and copyright
Any significant contribution from collaborators and students must be stated.
All unpublished work of other researchers and academics must not be used without their permission, and they must be duly mentioned.
All archives must be used in accordance with the rules established by archival sources.
5.2 Respect for confidentiality of information
All new information, data or concepts obtained through access to confidential manuscripts such as research funding applications or unpublished works must be used only after permission is obtained from the author.
5.3 Respect for scientific rigour and integrity
In obtaining, recording and analyzing data, as well as in communicating and publishing results, the principles of scientific rigour and integrity must be applied.
5.4 Respect for rules concerning conflict of interest situations
Any material, financial or other conflict of interest that could lead to misconduct or breach of integrity in research must be disclosed to the agencies sponsoring the research project, the university research institutions, specialized publications or funding organizations.
5.5 Respect for the requirements of the granting agencies regarding the responsible and ethical use of public funds
Complete and accurate information required to assess funding applications must be provided transparently and truthfully.
The funds allocated to research must be managed responsibly, based on sound accounting, financial and ethical principles.
6 - PROCEDURE FOR MANAGING CONFLICT OF INTEREST SITUATIONS
A conflict of interest, as indicated in its definition, is not a conduct, but a situation. However, the existence of such a situation can lead to misconduct or a breach in integrity of research. To prevent this from happening, certain actions are required:
6.1 Preventing situations of conflict of interest
Any person associated with research must avoid placing themselves in a situation where they may be led to choose between their personal interests and the interests of somebody else or the interests of RMC Saint-Jean or the interest of research.
6.2 Declare conflicts of interest
Any person associated with research must declare:
- Before any involvement in a decision-making process, their position when it places them in a real, potential or apparent conflict of interest;
- As soon as they become aware of it, any personal interest regarding a professional situation, whether it be an emotional attachment, financial interest or ties with an external organization;
- Any financial interest received personally that could lead to a conflict of interest or that could be perceived as such.
The declaration must be made in writing to the Office of the Academic Director.
RMC Saint-Jean commits to disclosing, in writing, to the granting agency concerned any conflict of interest likely to influence a decision regarding a grant or award application.
6.3 Guarantee conflict of interest management
This declaration must be processed as soon as possible by the Office of the Dean of Research in order to determine the measures that must be taken to prevent conflicts of interest or the appearance of conflicts of interest.
These measures can be, for example:
- Withdrawing the person from a decision-making process;
- Obligating the person, their relatives or associates, to divest themselves of their interests in a company;
- Modifying a research project or the terms of a contract;
- Implementing a process to have an independent person supervise the situation.
7 - PROCEDURE FOR PROCESSING ALLEGATIONS OF MISCONDUCT OR BREACH OF INTEGRITY IN RESEARCH
When there is an allegation of misconduct or breach of integrity in research, the procedure for processing this allegation is as follows:
7.1 Receiving allegations of misconduct or breach
- Any person (the “complainant”), internal or external to the institution, may file an allegation of misconduct or breach (hereinafter “complaint”) if they have a reasonable suspicion that a person has violated this policy.
- The complainant must file a written complaint identifying their name, contact information and the suspected person and describing the misconduct to the Office of the Academic Director.
- Complaints may also come from the granting agencies.
- Anonymous complaints will not be processed.
At all times:
- The complainant maintains control of their file; at any time, they may stop the process, unless it has become a criminal matter;
- The persons concerned (complainant and respondent) must be protected and must benefit from anonymity;
- Confidentiality of information is respected.
7.2 Preliminary review of the allegation of misconduct or breach
- The Office of the Academic Director reviews the complaint and has ten (10) working days to decide whether the complaint is admissible. To assist in its decision, it must work with the Office of the Dean of Research.
If the complaint is found to be inadmissible, the complainant is informed after ten (10) workings days of the decision and the reasons the complaint was rejected:
- If they have new information, the complainant may re-submit their complaint to the Office of the Academic Director.
- If they feel that their rights have been violated, the complainant has ten (10) working days to appeal to the Senate of RMC Saint-Jean by submitting in writing their application to have their complaint reassessed.
- The Senate receives the complaint and has ten (10) working days to decide whether or not the complaint is admissible. To assist in its decision, the Senate may ask other persons to advise it. The Senate’s decision is final.
- Once the preliminary review of the complaint’s admissibility has been completed, the Office of the Academic Director forwards it as soon as possible to the granting agency concerned with the information the latter deems necessary;
- If the complaint is found to be admissible, the Office of the Academic Director begins the investigation process;
- The Office of the Academic Director may decide not to begin the investigation process if, after having heard the person subject to the complaint, the facts are clear (for example, when a person subject to the complaint acknowledges the alleged facts or the review of the complaint would not add new facts regarding the allegation). In these exceptional cases, in order to follow up on assessing the admissibility of the complaint, it must prepare jointly with the Office of the Dean of Research an investigation report for the granting agency concerned; the complainant is also informed of this.
7.3 Investigation procedure
7.3.1 Appointment of the head of the investigation
- The Dean of Research is normally ex officio appointed as the person in charge of the investigation. However, if the complaint directly or indirectly involves this person, the Office of the Academic Director appoints another person deemed to be sufficiently impartial and competent in terms of integrity to proceed with reviewing the complaint. This person will act as “head of the investigation” (hereinafter).
- The person subject to the complaint (the “respondent”) is informed within five (5) working days, by the head of the investigation, of the filing of a complaint, the content of it, and the beginning of an investigation. The complainant is also informed.
7.3.2 Establishment of the investigation committee
- The head of the investigation establishes, within ten (10) working days, a complaint review committee made up of three (3) people with no link to the person(s) concerned in the complaint, including at least one person sourced externally.
- The committee members must be chosen for their competence in integrity, and at least one of them must be chosen for their expertise in the field of research targeted by the complaint. None of these persons may have a real, potential or apparent conflict of interest with the person or the research at issue. In the event that an officer cadet is involved, the committee must, in addition, also include one officer cadet.
7.3.3 Investigation process
The committee conducts and documents the investigation:
- The respondent and the complainant are invited to collaborate in the investigation and to submit any information that would help with impartially processing the complaint.
- When necessary, the committee may ask others to testify.
- During the investigation, the Senate, the Office of the Academic Director, the Office of the Dean of Research and the members of the complaint review committee shall protect the confidentiality of information and anonymity of persons.
The head of the investigation assembles a file containing all of the proceedings (complaints, documents consulted, exchanges of emails, requests for information and any other documents associated with the file):
- This file, retained in a locked condition for five (5) years in the office of the head of the investigation, contains all documentation associated with the committee’s activities;
- Access to this file is strictly limited to members of the complaint review committee.
7.3.4 Preliminary report preparation
- After the investigation, the committee prepares a “preliminary” report and forwards it within fifty (50) working days of the start of the investigation to the respondent and the complainant.
- This report summarizes the complaint, the investigation and the decision made regarding whether the complaint is founded, the impact assessment, whether the impact is serious or not, the alleged contravention and the committee’s recommendations.
- The complaint review committee may find the complaint “unfounded”, “founded, but not causing serious impacts” or “founded, causing serious impacts.”
- In making their decision, all of the members must try to reach a consensus. In the event that members cannot arrive at a consensus, a majority decision is made.
- The respondent and the complainant have ten (10) working days to react to the report.
7.3.5 Final report
- After receiving within the specified time frame reactions from the respondent and the complainant, the committee notes the reactions and adjusts its report as required, arriving at what becomes the “final” report.
- If the complaint is judged to be unfounded, the head of the investigation forwards the final report to the Office of the Academic Director, the complainant and the respondent to inform them of the committee’s conclusions. Then, the Office of the Academic Director forwards to the granting agency concerned a letter of conclusion for the complaint containing the information the agency deems necessary;
- If the complaint is judged to be founded, but the alleged contraventions are judged to not cause serious impact, the head of the investigation asks the respondent to quickly correct the situation. If the respondent accepts and makes the corrections deemed necessary, the file is closed, and the complainant is advised in writing of the corrections made. The head of the investigation forwards the final report to the Office of the Academic Director, the complainant and the respondent to inform them of the committee’s conclusions and the agreement reached with the respondent. Then, the Office of the Academic Director forwards the final report to the relevant granting agency.
If the complaint is judged to be founded, and the alleged contraventions are judged to cause serious impacts, the committee’s report is forwarded to the Senate of RMC Saint-Jean for follow-up and so that specific measures are taken as soon as possible. The report is also forwarded to the Office of the Academic Director.
- Within thirty (30) working days following the end of the investigation, the Senate sends a copy of the final report accompanied by the measures identified to the respondent, the complainant and the granting agency concerned;
- If a granting agency requested that the RMC investigate, the Senate sends a full copy of the report within the same time frame and in compliance with the Act respecting Access to documents held by public bodies and the Protection of personal information (R.S.Q., c. A-2.1). After this copy is sent, the Senate of RMC Saint-Jean remains available to make clarifications or provide additional information. Furthermore, the granting agencies reserve the right to impose their own sanctions based on their directives and policies;
- If it is confirmed that there was misconduct and that the situation justifies such a measure, the funds allocated by the granting agencies are withheld until the corrective measures deemed acceptable by the agencies are implemented.
7.3.6 Appeal procedure
- The complainant may appeal the committee’s decision if they believe that their rights have been violated. The complainant then has ten (10) working days to appeal by submitting in writing to the Senate their application to have their complaint reviewed.
- The respondent may appeal the committee’s decision if they believe that their rights have been violated. The respondent then has ten (10) working days to appeal by submitting in writing to the Senate their application to have their file reviewed.
After reviewing the file and the application for appeal, the Senate may:
- Confirm the committee’s decision;
- Ask the Office of the Academic Director to form another committee responsible for reviewing the appeal application and, if required, conducting a new investigation. To help it in its decision, the Office of the Academic Director may ask other persons for advice. The committee members must not be the same as on the first committee, but they must still have competency in terms of integrity and in the field of research targeted by the complaint. The appeal committee’s conclusions are final.
7.3.7 Retention of documents
- The complaint review committee’s final reports are retained under lock and key in the Office of the Dean of Research for two (2) years for complaints judged to be unfounded and for five (5) years for complaints judged to be founded, regardless of the seriousness of the impact.
- The Dean of Research ensures that all associated documents and files forwarded to third parties are destroyed when allegations have been rejected.
8 - SHARING OF RESPONSIBILITIES
Any person involved in research activities has the primary responsibility to ensure compliance with the highest standards of conduct with respect to integrity. More specifically, everyone has the following responsibilities:
Researchers are responsible for:
- Applying the principles of scientific integrity and rigour in collecting, recording and analyzing data, as well as in communicating and publishing the results;
- Obtaining permission from an author or authors before using new information, data or concepts obtained through access to confidential manuscripts, such as funding applications or unpublished works;
- Stating the exact source of information obtained by other researchers or in the context of other research, in particular when a discovery has previously been the subject of a communication or publication;
- Stating previous publications when using previously published research results;
- Using the archives in accordance with the rules established by archival sources;
- Obtaining permission from the author or authors to use a patented product or process;
- Ensuring that all persons who contributed to the content of a publication and who share responsibility for it are listed among the authors of published works, unless they have not given their authorization;
- Retaining in a secure, locked location, confidential data collected for a period of at least five (5) years or for the period mentioned in the informed consent form, after which they must destroy them so that they are no longer accessible;
- Making accessible, at all times, data to the persons concerned to the extent that the data collected during research belong to the persons who contributed to this research;
- Responsibly and ethically using the material or financial resources allocated to them for their research activities;
- Not taking advantage of these resources for personal benefit;
- Disclosing to agencies associated with research any conflict of interest that could influence their decision to ask a person to review manuscripts (e.g. scholarship or grant applications), experiment with new products or authorize work;
- Obtaining the necessary authorizations before beginning research with human beings (interviews, scenarios, questionnaires, experiments, etc.). For example: from RMC Saint-Jean and its ethics committee or from the granting agencies;
- Collaborating in all processes intended to manage an allegation of misconduct or a breach of integrity in research targeting research activities, in progress or completed, with which they are associated (including retaining and making available any document relevant to the assessment and review of an allegation);
- Being proactive in order to mitigate, as required, the consequences of misconduct or a breach of integrity in research, and being honest and consistent regarding the review’s conclusions;
- Keeping informed and participating in the evolution of best practices of integrity in research, integrating these into their research activities and promoting them, in particular within their own work teams;
The Senate is responsible for:
- Adopting this policy, following the advice of the Faculty Council;
- Taking the measures required against other stakeholders who do not respect their obligations;
- Respecting the decision of the complaint review committee during the appeal procedure.
8.3 Office of the Academic Director
The Office of the Academic Director is responsible for:
- Receiving complaints and ensuring compliance with investigative processes;
- Ensuring policy implementation and compliance.
8.4 Office of the Dean of Research
The Office of the Dean of Research is responsible for:
- Making all personnel and students at RMC Saint-Jean aware of the policy, and promoting it;
- Implementing material conditions to foster respect for principles of integrity;
- Promoting best practices in research integrity through awareness measures and continuing training in the RMC Saint-Jean community;
- Ensuring respect for the strictest standards of integrity concerning persons who engage in the collection, recording, citation, reporting and conservation of complaint data;
- Forming the committees responsible for reviewing complaints.
8.5 Faculty Council
The Faculty Council is responsible for:
- Recommending to the Senate that the policy be adopted;
- Ensuring that the policy is revised.
8.6 Complaint review committee
The complaint review committee is responsible for:
- Reviewing complaints submitted for misconduct or breaches of integrity in research, rendering a decision and making recommendations;
- Protecting the persons concerned by respecting the anonymity and confidentiality of information.
8.7 Office of the Commandant
The Office of the Commandant is responsible for:
- providing the Office of the Academic Director with the resources necessary for the implementation, evaluation and revision of the policy on integrity in research
9 - ADOPTION, IMPLEMENTATION AND DISSEMINATION OF THE POLICY
This version of the policy on integrity in research was recommended by the Faculty Council on January 20, 2022, and was then adopted by the Senate of RMC Saint-Jean, at Saint-Jean-sur-Richelieu, on March 15, 2022. It entered into force on March 15, 2022.
This policy is issued in all departments and services of RMC Saint-Jean.
10 - ASSESSMENT OF IMPLEMENTATION AND REVISION OF THE POLICY
As required, the Faculty Council may assess the policy’s implementation and revise it.
Additions or amendments made are approved by the Senate following the advice of the Faculty Council. As required, the Faculty Council establishes a committee responsible for revision. This committee carries out consultations with the departments and services concerned. Its recommendations are forwarded to the Faculty Council.
- Date modified: