Gap Analysis and Action Plan to support the implementation of The Concordat to Support Research Integrity Version 2 – July 2014 This document identifies the University’s existing systems, processes and procedures to support the five commitments of the Concordat and identifies further actions required to embed these. Factors have been identified and referenced against the Concordat document, which can be found at: http://www.universitiesuk.ac.uk/highereducation/Pages/Theconcordattosupportresearchintegrity.aspx Commitment #1 We are committed to maintaining the highest standards of rigour and integrity in all aspects of research Clause Evidence for current compliance 1. Researchers will: a. understand the expected standards of The University outlines its Research and Knowledge rigour and integrity relevant to their Exchange (RKE) Strategy here: research http://www2.mmu.ac.uk/media/mmuacuk/content/docume nts/rke/7875%20RKE%20Strategy%20Communication%20W EB.pdf The RKE strategy specifically addresses ways that the University can ensure that staff understand what is expected of them e.g. “Establish the PDR as the key instrument for managing and monitoring all research and knowledge exchange activity, and the setting of specific goals and targets for staff performance in this area.” MMU Guidelines on Good Research Practice: http://www2.mmu.ac.uk/media/mmuacuk/content/docume nts/rke/Guidelines%20on%20good%20research%20practice. doc Actions Work with HR to develop a leaflet of links to essential reading for Researchers. b. maintain the highest standards of rigour and integrity in their work at all times 2. Employers of researchers are responsible for: a. collaborating to maintain a research environment that develops good research practice and nurtures a culture of research integrity, as described in commitments 2 to 5 Engage with the Peer Review Process (RKE Strategy – “Establish and embed a mandatory university-wide peer review procedure to drive up the quality of research and knowledge exchange and improve the University’s success rate with customers and funders.” Adhere to the Guidelines on Good Research Practice Formalize regularity of review Ethics Framework procedures to engage with Continue review of Ethics Framework MMU RKE Strategy: http://www2.mmu.ac.uk/media/mmuacuk/content/docume nts/rke/7875%20RKE%20Strategy%20Communication%20W EB.pdf Specifically “Establish the PDR as the key instrument for managing and monitoring all research and knowledge exchange activity, and the setting of specific goals and targets for staff performance in this area.” Schedule events and informal sharing Initiatives for Researchers. Publish Information relating to Peer Review on the MMU website “Initiate, develop and nurture partnerships with international and world-leading organisations, and other strategically aligned stakeholders - including SMEs, the public sector, policy forums and the third sector.” 3. Funders of research expect: a. researchers to adhere to the highest standards of professionalism and integrity Strategy & Guidance PDRs b. employers of researchers to have procedures in place to ensure that Adhere to the Guidelines on Good Research Practice CoP dealing with allegations of misconduct Add links to website to the Research Councils/NHS/Other funders to ensure that researchers are aware that they must adhere to the standards outlined. Publish a review schedule with contact details, including a clear way for people to submit research is conducted in accordance with standards of best practice; systems to promote research integrity; and transparent, robust and fair processes to investigate alleged research misconduct http://www2.mmu.ac.uk/media/mmuacuk/content/docu ments/rke/CODE%20OF%20PRACTICE%20FOR%20DEALIN G.pdf Ethics Procedures Peer Review From RKE Strategy – “Adopt a proactive approach to peer review of outputs prior to submission for publication.” ideas for consideration at the next review of policies. 4. Where research is being conducted Add a section on website, include a collaboratively, and particularly within collaboration checklist to help researchers interdisciplinary or international e.g. if another institution is the lead you partnerships, there needs to be clear must provide a copy of the Ethical approval agreement on and articulation of the & full protocol to the Faculty Head of Ethics standards and frameworks that will with clear details of which aspects of the apply to the work research will take place at MMU. Commitment #2 We are committed to ensuring that research is conducted according to appropriate ethical, legal and professional frameworks, obligations and standards. Clause Evidence for current compliance Actions Researchers will: a. ensure that all research is Ethics Framework: Continue with reviewing Ethics Procedure & subject to active and http://www2.mmu.ac.uk/rke/ethics-forms/ Policies. appropriate consideration of ethical issues Provide clear step by step guidance (highlight amendment procedure). b. comply with ethical, legal and Stated in the Ethics Framework & Guidance on Good Research Provide links on websites to common professional frameworks, Practice professional frameworks, obligations and obligations and standards as standards. required by statutory and regulatory authorities, and by employers, funders and other relevant stakeholders 2. Employers of researchers are responsible for: a. having clear policies on ethical Ethics Policies/Forms: approval available to all http://www2.mmu.ac.uk/rke/ethics-forms/ researchers b. making sure that all researchers are aware of and understand policies and processes relating to ethical approval c. supporting researchers to reflect best practice in relation to ethical, legal and professional requirements d. having appropriate arrangements in place through which researchers can access advice and guidance on ethical, legal and professional obligations and standards 3. To support researchers and employers of researchers, funders of research will: a. clearly identify any specific codes of practice, legal requirements and other policies that researchers and employers of researchers are Documents to be revised using peer organisations/Research Councils/Charities as a reference point/benchmark drawing on good practice. Add clear guidance to the website. Liaise with Research Institute Directors and other senior management. Development of a mandatory online training module for all staff to complete. Provide key contacts on website. Available on the website and in documentation Provide clear links to other areas of the website. Provide FAQs, Twitter updates Contacts for advice both procedural and academic Website update Links to internal policies on the website Signpost all relevant policies from the RKE page also provide links to external frameworks Research Councils etc. expected to comply with b. explore ways of streamlining When reviewing documentation where requirements to reduce any possible ensure that it maps onto external duplication and inconsistency frameworks. Commitment #3 We are committed to supporting a research environment that is underpinned by a culture of integrity and based on good governance, best practice and support for the development of researchers. Clause Evidence for current compliance Actions 1. Employers of researchers will: a. embed the features listed in Compulsory RKE Induction for new academic/research staff Consult with Research Staff about future their own systems, processes training. and practices clear policies, HR website – Leadership, management and development & practices and procedures to Performance & Development Create a suite of training ‘Research support researchers Essentials’/’RESEARCH Academy’ to include i. suitable learning, training The University has a suite of mandatory training for managers leadership, bidding, ethics. and mentoring entitled “Management Essentials” (which includes equality and opportunities to support diversity training). Details of training on the University’s staff the development of development intranet pages at: Clear Communication strategy researchers http://www.mmu.ac.uk/humanresources/devandtrain/ ii. robust management systems to ensure that MMU’s Research and Knowledge Exchange Team also provides policies relating to staff development opportunities such as training. research, research integrity and researcher Training completions are reported to deans/directors in 6 monthly behaviour are management reports. implemented iii. awareness among The University operates a mandatory PDR (professional researchers of the development review) Scheme, which includes a career standards and behaviours development discussion. PDR completions are monitored and that are expected of them reported in the annual staff development report. iv. systems within the research environment that identify potential concerns at an early stage and mechanisms for providing support to researchers in need of assistance b. work towards reflecting recognised best practice in their own systems, processes and practices c. implement the concordat within their research environment The University also offers a programme for Academic Leadership and Management which specifically focuses on the requirements of academic managers and workshops to support research supervisors. Grant applications are signed off by the Research Office, with principal investigators supported with advice on the grade of research staff member needed for the project and on costings for the post. MMU offers a regular programme of funding opportunities to encourage and support early stage career researchers. The Research Accelerator Grant has been created to provide funding to Early Career Researchers and the Knowledge Exchange and Innovation Fund makes awards to encourage staff to venture into new research and knowledge exchange areas. See: http://www.mmu.ac.uk/staff/fundingopportunities/ RKE Strategy - Implement research and knowledge exchange management information systems, which enable the collection and development of performance metrics at the individual, centre, faculty and institutional level. At a local level, buddies and mentors are arranged with staff as Add a review schedule to all appropriate, with a Guide to Mentoring available online here: processes/policies/guidance and map onto external stakeholders and relevant http://www.mmu.ac.uk/humanresources/pdf/general/Mentoring. frameworks. pdf Head of Research and Ethics and Research Governance Manager to attend senior team meetings and appropriate Research events. 2. Funders of research are responsible for a. promoting adoption of the No Action Required No Action Required concordat within the research community b. supporting the No Action Required No Action Required implementation of the concordat through shared guidance, policies and plans Commitment #4 We are committed to using transparent, robust and fair processes to deal with allegations of research misconduct should they arise. Clause Evidence for current compliance Actions 1. Employers of researchers have: a. the primary responsibility for http://www2.mmu.ac.uk/media/mmuacuk/content/documents/rk Updating of Code of Practice in process. investigating allegations of e/CODE%20OF%20PRACTICE%20FOR%20DEALING.pdf research misconduct. b. to ensure that any person http://www2.mmu.ac.uk/media/mmuacuk/content/documents/h involved in investigating such uman-resources/a-z/guidance-procedures-andallegations has the handbooks/Disciplinary_Procedure.pdf appropriate knowledge, skills, experience and authority to Staff training: do so. Disciplinary and Capability Training c. responsibility for taking Issue clear guidance of steps for how to appropriate steps to remedy investigate misconduct and steps to follow to any situations arising from an redress include notifying funders/stakeholders investigation. This can include as necessary. imposing sanctions, correcting the research record and reporting any action to regulatory and statutory bodies, research participants, funders or other professional bodies as circumstances, contractual obligations and statutory requirements dictate. d. to be mindful that minor infractions, where there is no evident intention to deceive, may often be addressed informally through mentoring, education and guidance. 2. Researchers will: a. act in good faith with regard to allegations of research misconduct, whether in making allegations or in being required to participate in an investigation b. handle potential instances of research misconduct in an appropriate manner; this includes reporting misconduct to employers, funders and professional, statutory and regulatory bodies as circumstances require 3. As part of existing mechanisms and conditions of grant, employers of researchers should already: Issue guidance regarding minor infractions. Ensure that this is included in the Guidelines. Provide a process map with clear named contacts and details of timeframes and responsibilities. a. Have clear, well-articulated and confidential mechanisms for reporting allegations of research misconduct b. Have robust, transparent and fair processes for dealing with allegations of misconduct that reflect best practice c. ensure that all researchers are made aware of the relevant contacts and procedures for making allegations d. act with no detriment to whistleblowers making allegations of misconduct in good faith Create process map and ensure expectations are outlined in the Guidelines. Create process map and ensure expectations are outlined in the Guidelines. Speak to HR about distributing Guidelines. Fair treatment at work framework http://www2.mmu.ac.uk/media/mmuacuk/content/documents/h uman-resources/a-z/policies-schemes-and-terms-conditions/Fair_Treatment_at_Work.pdf Public Interest Disclosure (“Whistleblowing”) Policy http://www.finance.mmu.ac.uk/uploads/5/MMU%20Public_Intere st_Disclosure_Policy_Feb_2012.pdf e. provide information on investigations of research misconduct to funders of research and professional and/or statutory bodies as required by their conditions of grant and other legal, professional and statutory obligations Include appropriate expectations within guidelines. Guidelines should make clear that we expect all to act responsibly and conduct their research with a high moral code. Provide a process map and include who to inform when. f. support their researchers in providing appropriate information to professional and/or statutory bodies g. provide a named point of contact or recognise an appropriate third party to act as confidential liaison for whistleblowers or any other person wishing to raise concerns about the integrity of research being conducted under their auspices. This need not be the same person as the member of staff identified to act as first point of contact on research integrity matters, as recommended under Commitment #3. 4. Funders of research will: a. have clear expectations of what constitutes research misconduct b. ensure that recipients of funding are aware of requirements regarding the investigation and reporting of research misconduct, and that these are openly stated Info on website about who to contact for information. Provide a named contact and the process to follow. Use the frameworks of the Research Councils/NHS etc. to inform our own guidance. Liaise with Research Development Managers to consider the information provided to researchers if they are successful in applying for grants Commitment #5 We are committed to working together to strengthen the integrity of research and to reviewing progress regularly and openly. Clause Evidence for current compliance Actions 1. employers of researchers should RKE Strategy - Issue Board of Governors and Executive with regular present a short annual statement reports on research and knowledge exchange activity. to their own governing body Make the annual update of the Research and that: Knowledge Exchange strategy an Executive priority. a. provides a summary of Annual Monitoring and Evaluation statistics relating to Evaluate training for research staff. Implement actions and activities that postgraduate researcher training are collated by the Graduate a process for people to feed in issues that have been undertaken to School. might have been raised in PDRs. support and strengthen understanding and application of research integrity issues (for example postgraduate and researcher training, or process reviews) b. provides assurances that the Implement a review schedule. processes they have in place for dealing with allegations of misconduct are transparent, robust and fair, and that they continue to be appropriate to the needs of the organisation c. provides a high-level Review processes for collating and storing statement on any formal information relating to investigations. investigations of research misconduct that have been undertaken d. that improves accountability, and provides assurances that measures being taken continue to support consistently high standards of research integrity, this statement should be made publicly available. 2. Employers of researchers also need to be confident that the procedures and practices they have in place are robust. Given the changing nature of concerns relating to research integrity and the emergence of new types of research, it is important that employers periodically review their processes to ensure that they remain ‘fit for purpose’. Implement a review schedule.