Policy 7.3 - Responsible Conduct of Research Policy

The official version of this policy is housed with the University Secretariat.  In the event of a discrepancy, the official version will prevail. Click here for a printable version of this policy. 

Approving Authority: Board of Governors & Senate
Responsible Office: Office of the Vice-President (Research)
Responsible Officer: Vice-President (Research)
Original Approval Date: January 27, 2015
Date of Most Recent Review: June 21, 2023
Previous Revisions: Editorial change: September 22, 2021

1. Preamble

1.1.  The University of Guelph (“University”) expects the highest standards of integrity in every aspect of Research carried out by all members of its academic community.  For the purposes of this document, “Research” encompasses the creation and application of new knowledge or the use of existing knowledge in new and creative ways through Research, scholarly, and artistic work.

1.2.  The University is committed to exemplifying the values and behaviours associated with Research integrity including trust, honesty, fairness, rigour, respect, responsibility, and courage, which are adopted from the International Centre for Academic Integrity (www.academicintegrity.org). In particular, we recognize that Research must be built on a foundation of trust. Researchers must have trust in the data and results reported by others, and trust that when undertaking collaborative projects that they will be appropriately recognized for their contributions. The public and funders must trust that Research funding will be managed and spent appropriately and accountably, and society must have confidence in the Research disseminated by the University. Maintaining the trust and confidence of both the academic community and the public is a core responsibility of the University. As such, misconduct in Research is incompatible with the mission and ethical standards of the University.

2. Purpose

2.1.  This document provides guidance on expectations for Research integrity, actions that constitute Research Misconduct, and definitions and contextual information for this Policy. The processes to respond to alleged Research Misconduct are described in the Responsible Conduct of Research Procedures.

2.2.  This Policy confirms the University’s continued commitment to the highest standards of integrity in all aspects of Research, including seeking funding, conducting Research, and reporting the results.

3. Jurisdiction/Scope

3.1.  Except as otherwise stated, the Policy and Procedures documents apply to all while conducting Research in a capacity defined by their relationship with the University (“Researcher(s)”). This includes faculty (including tenure-track, contractually limited, adjunct, retired, emeriti and emeritae professors, and visiting professors), Veterinarians, librarians, administrators, postdoctoral scholars, sessional instructors, volunteers, staff, and students (including undergraduate, graduate, and professional students), irrespective of the present source of their salary or stipend.

3.2.  In the event the implementation of this Policy conflicts with relevant provisions of applicable collective agreements or employee group agreements, the relevant provisions of agreements will prevail.

3.3.  Where allegations of Research Misconduct arise out of activities carried out by students, the Associate Vice-President Research Services (AVPRS) and the Dean of the student’s college (or their delegate) will determine whether it is appropriate to (a) proceed under this Policy or (b) proceed under the Academic Misconduct policy, if the incident arises from activities related to an academic assignment. If a student is involved in alleged misconduct relating to Research funded by a Tri-Agency, the Tri-Agency will be informed.

3.4.  Capitalised words and expressions used in this Policy and its accompanying Procedure have a meaning attributed to them as set out in the Definitions at Section 4 of this Policy.

4. Definitions

4.1.  Advisor means a person who has agreed to act in an advisory capacity to a Respondent, Complainant, or Witness. Such individuals act in accordance with this Policy and if members of the University are deemed, in so doing, to perform part of their academic duties.  Advisors act without remuneration from the University for this service.

4.2.  Allegation is a written declaration, statement, or assertion that presents evidence to the effect that there has been, or continues to be, Research Misconduct, the validity of which has not been established. Submission of an Allegation prompts the start of actions described in the Responsible Conduct of Research Procedures.

4.3.  Appeal Committee is an ad hoc committee created and chaired by the Vice-President Research, which will be composed of three individuals (in addition to the Chair), who may include the Associate Deans of Research and Graduate Studies. At least one member shall have expertise in the discipline of the Respondent.

4.4.  Appeal Decision is the decision made by the Appeal Committee, based on all reports of the Investigation Committee, as well as any new evidence provided.

4.5.  Bad Faith refers to intent to deceive or holding a dishonest or malicious purpose. Bad Faith allegations are allegations made without sufficient grounds or evidence, contain deliberately incomplete or inaccurate statements, or are vexatious or malicious.

4.6.  Bargaining Unit is a group of employees represented by a union.

4.7.  Complainant is a person submitting an Allegation.

4.8.  Dean means the dean of the college in which the alleged Research Misconduct has occurred, as appropriate, or if the Respondent to the Allegation of Research Misconduct resides outside an academic department or college, the responsibilities of the Dean under this Policy will be assumed by an appropriate senior-level University official as appointed by the AVPRS.

4.9.   Dean’s Decision represents the relevant Dean’s decision at the Inquiry Stage whether to dismiss the Allegation or proceed to an Investigation.

4.10.  Disciplinary Action is a punishment related to Research Misconduct.  The disciplinary action may include ending some or all Research Privileges or terminating employment, among others.

4.11.  Expert is a person called to provide information to an Investigation Committee, who has requisite skill or knowledge relating to a particular subject as determined by the Investigation Committee based on credentials or demonstrated experience.

4.12.  Final Decision is the determination of an Investigative Committee’s finding, or no finding, of Research Misconduct.  If there is a finding of Research Misconduct, the specific offences will be noted, e.g., fabrication, plagarism, as described in Section 4.26.

4.13.  Final Report is a report prepared by the Dean and AVPRS (where there are substantiated Allegations) and will include the Investigation Committee Report, the Remedial Action, and Disciplinary Action, if any.

4.14.  Good Faith Allegation means an allegation that is not malicious or frivolous made by a Complainant who has reasonable grounds to believe that Research Misconduct may have occurred.

4.15.  Honest Error means a mistake or omission committed by a Researcher that was made unintentionally or unknowingly, and which when identified is rectified by the Researcher such as described in Section 5.1.12. If there is evidence of knowledge of or deliberate intent to commit Research Misconduct or actions to hide Research Misconduct, then the actions are not honest errors.

4.16.  Inquiry is the process of reviewing an Allegation to determine (i) whether the Allegation is responsible, (ii) the particular policy or requirements of responsible conduct of Research that may have been breached, and (iii) whether an Investigation is warranted. The Inquiry is a preliminary assessment process; its purpose is not to determine whether or not Research Misconduct occurred.

4.17.  Inquiry Report is a report prepared by the Dean who conducted the Inquiry, which includes reasons for the Dean’s Decision and a summary of the evidence used to support the Dean’s Decision.

4.18.  Investigation is a systematic process of examining an Allegation, collecting and examining the evidence related to the Allegation, and making a decision as to whether a Research Misconduct has occurred.

4.19.  Investigation Committee is a committee to investigate an allegation of Research Misconduct pursuant to Section 1.3.3 of the Responsible Conduct of Research Procedures, comprising at a minimum the AVPRS (or designate), a member of the Senate Research Board, and an external member not affiliated with the University of Guelph with the appropriate experience.

4.20.  Investigation Committee Report is a report prepared by the Investigation Committee that comprises the Final Decision, the finalised Preliminary Report and recommendation for Remedial Action.

4.21.  Preliminary Report is a report produced by the Investigation Committee within sixty-five (65) working days of the establishment of the Investigation Committee.

4.22.  Relevant VP refers to the University of Guelph Vice-President to which the Respondent directly or indirectly reports.

4.23.  Remedial Action is a recommended or required activity of the Respondent that will depend on the severity of the breach and can include, for example, issuing a letter of concern to the Researcher, and correction of the research record. It does not include academic sanctions/discipline.

4.24.  Research means all forms of funded and unfunded scholarly, scientific, artistic and professional work and related activities based on intellectual investigation aimed at discovering, interpreting, revising, disseminating, or publishing knowledge.

4.25.  Researcher(s) are individuals who carry out Research in a capacity defined by their relationship with the University, irrespective of the source of their salary or stipend; that is, faculty (including tenure-track, contractually limited, adjunct, retired, emeriti and emeritae professors, and visiting professors), Veterinarians, librarians, administrators, postdoctoral scholars, sessional instructors, volunteers, staff, and students (including undergraduate, graduate, and professional students).

4.26.  Research Misconduct is broadly understood to mean offences against Research integrity, described, without limitation, in Section 5.1.  Research Misconduct does not include those factors intrinsic to the process of academic Research, such as honest error, conflicting data, or honest differences in interpretation or assessment of data or of experimental design. Intent is not required to determine whether Research Misconduct occurred, but intent may inform the severity of sanctions imposed. Research Misconduct includes but is not limited to:

4.26.1. Fabrication: Making up data, source material, methodologies or findings, including graphs and images.

4.26.2. Falsification: Manipulating, changing, or omitting data, source material, methodologies or findings, including graphs and images, without acknowledgement and explanation.

4.26.3. Destruction of Research records: The destruction of one's own or another's Research data or records, in particular to avoid detection of misconduct or in contravention of the applicable funding agreement, institutional policy, laws, regulations or professional or disciplinary standards.

4.26.4. Plagiarism: Presenting or 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.

4.26.5. Redundant publications: The re-publication of one's own previously published work or data or part thereof, in the same or another language, without adequate acknowledgment of the source, or justification.

4.26.6. 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 and who have consented to authorship, or agreeing to be listed as author to a publication for which one made little or no material contribution.

4.26.7. Inadequate acknowledgement: Failure to appropriately recognize contributions of others in a manner consistent with their respective contributions and authorship policies of relevant publications.

4.26.8. Mismanagement of conflict of interest: Failure to appropriately manage conflict of interest, in accordance with applicable policies including: the Conflict of Interest Policy for University of Guelph Employees or the appropriate collective agreement conflict of interest provisions; Article 8: Conflict of Interest and Conflict of Commitment for members under the University of Guelph Faculty Association (UGFA) Collective Agreement; Article 17:  Conflict of Interest and Conflict of Commitment for employees under the UGFA Collective Agreement Unit 2; and the conflict of interest policies and procedures of Research funding agencies or organizations which require adherence to such policies and procedures as a condition of application for or receipt of Research funding from them.

4.26.9. Misrepresentation in Research applications and documents including: providing incomplete, inaccurate or false information in a grant or award application or related document; applying for or holding an 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; and listing of co-applicants, collaborators or partners without their agreement.

4.26.10. Mismanagement of funds: Using grant or award funds for purposes inconsistent with the policies of the University, relevant funding agency or organization; misappropriation of grant or award funds; contravention of financial policies and guidelines of a funding agency or organization; or providing incomplete, inaccurate, or false information on documentation for expenditures from grant or award accounts.

4.26.11. Failure to comply with relevant policies, laws, or regulations for the conduct of Research, or failure to obtain appropriate approvals, certifications or permits before conducting Research activities, including, but not limited to: 2nd edition of Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans (TCPS 2); Canadian Council on Animal Care Policies and Guidelines and the Animals for Research Act; Agency policies related to the Canadian Environmental Assessment Act; Licenses required for Research in the field; Canadian Biosafety Standards and Guidelines; Controlled Goods Program; Canadian Nuclear Safety Commission (CNSC) Regulations; and, Canada’s Food and Drug Act.

4.27.  Research Privileges are special rights, advantages, or benefits of being a university researcher.  These include being able to conduct Research that requires approvals, certifications, or permits (including those listed in Section 4.26.11); having a laboratory; applying for, holding, or spending from grants; supervising students; and hiring researchers to work on projects.

4.28.  Respondent is person alleged to have committed Research Misconduct.

4.29.  Responsible Allegation (i) is based on facts and evidence, (ii) refers to Research Misconduct as defined at the time the alleged breach occurred, (iii) is made in Good Faith, and (iv) is not the subject of a previous investigation.

4.30.  Witness means a person who testifies before the Investigation Committee.

5. Policy

5.1.  Research Integrity: Researchers shall strive to conduct Research honestly, accountably, openly, and fairly.  In addition, Researchers shall follow the requirements of applicable institutional policies and professional and disciplinary standards and shall comply with applicable laws and regulations.  Researchers are expected to:

5.1.1.  Use a high level of rigour in proposing and performing Research; in recording, analyzing, and interpreting data; and in reporting and publishing data and findings.

5.1.2.  Keep complete and accurate records of data, methods, and findings, including graphs and images, in accordance with the applicable funding agreement, institutional policies, laws, regulations, and professional or disciplinary standards in a manner that will allow verification or replication of the work by others. In the absence of a longer applicable requirement, these data and records shall be maintained for at least seven years. These requirements survive retirement, leaving or ending employment or enrolment at the University.

5.1.3.  Reference, accurately attribute, and where applicable, obtain permission for the use of all published and unpublished work, including data, source material, methodologies, findings, graphs, and images.

5.1.4.  Include as authors, with their consent, all those and only those who have materially or conceptually contributed to and share responsibility for the contents of the publication, document, or work, in a manner consistent with their respective contributions and authorship policies of relevant publications.

5.1.5.  Acknowledge, in addition to authors, all material contributors and contributions to Research, including writers, funders, and sponsors.

5.1.6.  Manage conflicts of interest in accordance with University of Guelph policies and procedures and adhere to policies and procedures of Research funding agencies or organizations that require adherence to such policies and procedures as a condition of application for, or receipt of, Research funding from them.

5.1.7.  Obtain approvals and training for Research as required by the University, or the policies of Research sponsors/agencies including, but not limited to, Research involving animals, human participants, biohazards, radioisotopes, national security, and environmental impact.

5.1.8.  Use Research funds (e.g., grants, awards, scholarships) in accordance with contracts and legal agreements with funders and the policies of the University.

5.1.9.  Provide complete and accurate information in funding applications and related documents and represent themselves, their Research and their accomplishments, consistent with the norms of the relevant field; ensure others listed on their applications have agreed to be included; and certify that they are not currently ineligible to apply for or hold funds from NSERC, SSHRC, CIHR or any other Research funding organization for reasons of Research Misconduct such as ethics, integrity or financial management policies.

5.1.10.  Report in Good Faith an allegation of Research Misconduct in accordance with this Policy.

5.1.11.  Proactively disclose and rectify Honest Errors or Research Misconduct, for example, by correcting the Research record, providing a letter of apology to those affected by the breach, or repaying funds.

5.2.  Confidentiality

5.2.1.  The University and all individuals involved in this process will take reasonable steps to protect the confidentiality of information gathered pertaining to any Allegation, Inquiry, or investigation of Research Misconduct falling under the scope of this Policy, to safeguard all against unsubstantiated Allegations, to protect the rights of those involved, and to preserve the integrity of the Inquiry and Investigation.

5.2.2.  The University is subject to access to information and privacy laws, including the Freedom of Information and Protection of Privacy Act (Ontario), which creates a right of access to records under the custody and control of public bodies subject to specific and limited exceptions. The University is also subject to requirements for the reporting of Research Misconduct by certain agencies or organizations, which may involve disclosing the discipline imposed, if any, and the identity of Respondents and Complainants.

5.3.  Wrongful Allegations

5.3.1.  Where an Allegation was not made in Good Faith, the University will take appropriate preventative and corrective action, including academic sanctions, and will, where warranted, hold individuals responsible in accordance with applicable collective agreement provisions, terms of employment or other University Policies and Procedures.

5.3.2.  No disciplinary measures shall be taken against the Complainant if the Complaint is found to have been made in Good Faith, even when the Allegation cannot be substantiated. Moreover, efforts will be made to ensure that no retaliatory action is taken against the Complainant in such cases.

5.4.  Retaliation or Reprisal

5.4.1.  For individuals who engage in acts of retaliation or reprisal (such as threats, defamation, intimidation, or harassment) against Complainants and/or Respondents who have been acting in Good Faith, the Dean, in consultation with the appropriate employee group association, may apply or recommend the application of appropriate sanctions consistent with University policies.

6. Relevant Legislation – see attached chart for legislation

6.1.  Animals for Research Act

6.2.  Canadian Environmental Protection Act

6.3.  Controlled Drugs and Substances Act

6.4.  Controlled Goods Regulations

6.5.  Copyright Act

6.6.  Defence Production Act

6.7.  Environmental Protection Act

6.8.  Excise Act

6.9.  Food and Drugs Act

6.10.  Guidance for Clinical Trial Sponsors

6.11.  Human Pathogens and Toxins Act

6.12.  Health of Animals Act

6.13.  Nuclear Safety and Control Act

6.14.  Occupational Health and Safety Act

6.15.  Personal Health Information Protection and Electronic Documents Act

7. Related Policies, Procedures & Documents

7.1.  Procedure for Policy 7.3 Responsible Conduct of Research Policy

7.2.  Agreement on the Administration of Agency Grants and Awards by Research Institutions

7.3.  Canadian Council on Animal Care

7.4.  Commercialization Policy

7.5.  Conflict of Interest Policy for University of Guelph Employees

7.6.  Industrial Security – Government of Canada’s Contract Security Program

7.7.  Intellectual Property Policy

7.8.  National Institutes of Health (NIH), Human and Health Services (HHS) and Public Health Service (PHS) Financial Conflicts of Interest Regulation 42 CFR Part 50 and 45 CFR Part 94

7.9.  National Security Guidelines for Research Partnerships

7.10.  Safeguarding Your Research

7.11.  Tri-Agency Framework: Responsible Conduct of Research (2021)

7.12.  Tri-Agency Guide on Financial Administration

7.13.  Tri-Agency Open Access Policy on Publications

7.14.  Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans – TCPS 2 (2022) 

7.15.  UGFA Collective Agreement Unit 1 and Unit 2