18th February 2015 Procedure for the Ethical Review of Research Projects SOAS, University of London 1. Aim and Scope of the Procedure SOAS anticipates the highest ethical standards of its researchers. The School’s Research Ethics Policy, which is aligned with The Concordat to Support Research Integrity, sets out the commitments expected of SOAS and its researchers to maintain a research environment in which best research practice is developed and a culture of research integrity nurtured. Ethical review of SOAS research projects constitutes one of the mechanisms by which SOAS and its researchers meet this commitment to research integrity. An ethical review is an approval process to ensure that SOAS research projects, whether funded or not, meet the requirements of the Research Ethics Policy and associated guidance such as the School’s document on Using Personal Data in Research: A Code of Practice for Staff and Students. The review ensures that rigorous ethical consideration has been undertaken by the researcher and will identify any potential ethical problems before the research project starts. Research organisations in receipt of research grants from the Higher Education Funding Council for England (HEFCE) are required to provide assurance of their compliance with the Concordat to Support Research Integrity through routine audit. Ethical review is a multi-stage, and potentially iterative, process. It is not a substitute for the proper consideration of ethical issues by the researcher. When drafting a research proposal, ethical considerations should be taken into account from the outset, using the SOAS Research Ethics Policy and other SOAS documents, as well as any ethical guidance and codes of practice which are specific to the researcher’s discipline. Research funders will often require that ethical issues, as well as steps to mitigate risks, are addressed explicitly on grant applications. Where necessary, researchers should initially seek advice on ethical concerns from their Head of Department or their Research Tutor as appropriate. Please note that research which is not captured by this procedure must still meet the requirements of SOAS Research Ethics Policy. 2. Status This procedure was approved by the Research & Enterprise Committee on 18/02/2015. It supersedes its previous version, dated 30 April 2009, and will be updated as necessary to take account of developments in ethical standards across the Higher Education sector. 1 18th February 2015 3. Who Needs Ethical Review? Any SOAS researcher might need ethical review: It “applies equally to SOAS staff and SOAS students conducting primary research* at any level, and to any other person, regardless of their status, engaged in research under the auspices of SOAS, or on behalf of, or in association with, SOAS (for example, independent contractors, consultants, visiting members of staff, staff from other institutions, emeritus staff, and staff on honorary appointments)” (SOAS Ethics Policy (2015), pp. 1-2). 4. When Is Ethical Review Required? Ethical review is required: After a research proposal has been drafted and ethical consideration has taken place, but Before the start of the research project Researchers must complete an ethical review application form and submit it to the appropriate reviewer together with a copy of the research proposal. If the reviewer recommends changes, it is the applicant’s responsibility to make these changes and resubmit a revised ethical review application form. Ethical approval is not granted until the changes recommended by the review process have been incorporated, and a revised application has been approved. The research phase of the project must not start until ethical approval has been confirmed. 4a. You are staff researcher You will need to undertake an ethical review if you plan to carry out primary research1; or if you were given ethical clearance previously but your research methodology has substantially changed; or if you are conducting longitudinal research that may require separate ethical reviews at different stages of the project. You will also need to comply with any funder’s requirements. 4b. You are a student 1 Research is considered to be ‘primary’ unless it deals only with materials that are clearly in the public domain already. In case of any doubt, researchers should err on the side of caution and complete a review. 2 18th February 2015 You will need ethical review if: You are a research student undergoing MPhil upgrade or whose research plans have changed materially since then. You are an undergraduate or taught postgraduate student and plan to do primary research In any other circumstances where you or your tutor/supervisor believes that ethical clearance would be necessary or beneficial, given the issues involved: for example, if you were given ethical clearance previously but your research methodology has substantially changed; or if you are conducting longitudinal research that may require separate ethical reviews at different stages of the project. 3 18th February 2015 5. What do you need to do? A) Procedure for Staff Researcher You are planning for… Externally-funded Projects Research Project (excluding Other circumstances externally funded projects) 1) Form to complete First-stage Ethical Review, also First-stage Ethical Review First-stage Ethical Review annexed to the Institutional Approval Form given by the Research Office as you apply for external funding Send your form to The Research Office Your Faculty Office The Research Office Reviewer Your Funding Officer Your Faculty Officer Your Associate Dean for Research Delay for response 1 week 1 week 1 week 2) If clearance is not granted, Second-stage Ethical Review Second-stage Ethical Review Second-stage Ethical Review form to complete Send your form to Your Associate Dean for Research Your Associate Dean for Research Your Associate Dean for Research Reviewer Associate Dean for Research and Associate Dean for Research and Associate Dean for Research and possibly the Research Ethics possibly the Research Ethics possibly the Research Ethics Panel depending on complexity. If Panel depending on complexity. If Panel depending on complexity. If necessary, the ADR may consult necessary, the ADR may consult necessary, the ADR may consult with any other academic with any other academic with any other academic colleagues inside or outside SOAS colleagues inside or outside SOAS colleagues inside or outside SOAS whose views are considered by whose views are considered by whose views are considered by the ADR to be relevant. the ADR to be relevant. the ADR to be relevant. Delay for response 2 weeks; longer if the Research 2 weeks; longer if the Research 2 weeks; longer if the Research Ethics Panel needs to grant the Ethics Panel needs to grant the Ethics Panel needs to grant the approval approval approval 4 18th February 2015 Approval form to be sent to ADR and Research Office ADR and Research Office ADR and Research Office Records of the outcome of the ethical review will be retained by the Research Office in the case of externally funded grant proposals and applications made in other circumstances. The Faculty Office will keep a record for all other types of leave. Researchers should ensure that they retain their own copy of ethical approvals as part of their project’s key documentation. B) Procedure for Research Student You are… 1) Form to complete About to upgrade Research Ethics Checklist (within MPhil upgrade form: https://www.soas.ac.uk/doctoralschool/forms/) Send your form to Research Tutor with upgrade form Reviewer Research Tutor Delay for response 1 month 2) If clearance is not granted, Second-stage Ethical Review form to complete Send your form to Research Tutor. Those that require further referral should be sent to the ADR by the Research Tutor. Reviewer Research Tutor then Associate Dean for Research if required. If the Associate Dean refers the application, possibly also the Research Ethics Panel depending on complexity. If necessary, the ADR may consult with any other academic colleagues inside or outside SOAS whose views are considered by the ADR to be relevant. Delay for response 2 weeks; longer if the Research Ethics Panel needs to grant the approval The outcome of this process for Staff and Research Students is: Ethical clearance is granted 5 18th February 2015 Ethical clearance is not granted and the research proposal is rejected on ethical grounds. This would normally occur only where the research is fundamentally incompatible with the School’s Research Ethics Policy or the research otherwise raises ethical concerns which are impossible to resolve. Ethical clearance is not granted and the proposal is referred back to the researcher: in this case, make the researcher should make the recommended changes and re-submit following the procedure from 2). Provisional ethical clearance is granted, subject to a final ethical review by the Research Ethics Panel once external research funding has been awarded. The ESRC recognises that, as most grant applications are not successful, it is wasteful for institutions to submit research proposals to ethical review prior to the award. Decisions of the Associate Dean of Research, or the Research Ethics Panel should the Associate Dean refer the application, are final and are not subject to appeal. Records of the outcome of the ethical review for research students will be retained by the Doctoral School Registry. Research students should ensure that they retain their own copy of ethical approvals as part of their project’s key documentation. Records of the outcome of the ethical review for research staff will be retained by the Faculty and the Research Office. Research staff should ensure that they retain their own copy of ethical approvals as part of their project’s key documentation. Procedure for taught Students You are… An undergraduate conducting primary research A PGT conducting primary research 1) Form to complete with Complete the Taught Student Ethical Review Complete the Taught Student Ethical Review form tutor/supervisor’s guidance form Send your form to Course convenor Course convenor or tutor as advised by the Department Reviewer Course convenor Course convenor or tutor as advised by the Department Delay for response 3 weeks after the departmental deadline 3 weeks after the departmental deadline 6 18th February 2015 2) If clearance is not granted, One resubmission permitted One resubmission permitted Research ethics applications will be retained until 6 years after the end date of the externally funded research project (as per the retention schedule2) or if longer as per the funder’s terms and conditions. Other types of research ethics applications will be held on record until informed that the research has ended. 6. What if the Research Involves Another Institution? Where the proposed research involves SOAS staff collaborating with staff in other institutions, it may be more appropriate for the research proposal to be evaluated under the ethical review procedures of one of the other partner institutions. In such cases, SOAS would accept the outcome of the other institution’s review, rather than conducting its own ethical review. The ESRC recognises that in collaborative projects, it is undesirable for ethical review to be duplicated. Researchers should indicate on the First-stage Ethical Review form whether a proposal has been or is to be evaluated according to another institution’s ethical review procedures. If the proposed partner institution is not a UK Higher Education institution, the Associate Dean for Research must verify that the ethical approval procedure used is consistent with SOAS’s ethical review procedure. Final SOAS approval of the research project will not be granted until the staff member has demonstrated that ethical clearance has been gained from the partner institution. 2 https://www.soas.ac.uk/infocomp/recordsmanagement/retention/ 7 18th February 2015 7. What Is the Role of the Research Ethics Panel? SOAS maintains a Research Ethics Panel to: (a) consider ethical matters relating to externally and internally funded research, and all research involving human participants. (b) provide advice to academics and students on ethical matters relating to research in order to ensure that such work complies with recognised ethical standards, that the public, staff and students are protected from harm, and that the reputation of the School is safeguarded. (c) consider research proposals, publications and other outputs which are referred to the Panel and to assess the ethical issues raised by projects submitted to it for consideration, and to grant or withhold approval. (d) consider requests to embargo hard and soft copies of PhD theses. (e) review and revise the Ethics policy and Research governance policy (including procedures for dealing with allegations of research misconduct) as necessary with a remit to conduct the final ethical review of research proposals by its Staff and Research Students which are referred to it by an Associate Dean for Research. In this respect, the panel performs the role assigned to a research ethics committee in the ESRC’s Research Ethics Framework. The panel is chaired by the Pro-Director Research & Enterprise. The Head of the Doctoral School, the Associate Deans for Research, and the Research Manager are members ex officio; one additional senior member of academic staff is nominated by each faculty; an external academic member from outside SOAS is appointed by the Pro-Director. The panel meets once a term, but may also choose to conduct its business ‘virtually’. Decisions on applications will be made by majority voting. It may seek advice from appropriate academic colleagues inside and outside SOAS. Decisions of the Research Ethics Panel are final and are not subjected to appeal. The Research Ethics Panel does not consider appeals on behalf of Undergraduate or PostGraduate taught students. Contacts For Staff and PGRs: Associate Dean for Research, Arts & Humanities Associate Dean for Research, Languages & Cultures Associate Dean for Research, Law & Social Sciences Research Office For Taught Students Couse convenor or Departmental Research Coordinator 8 18th February 2015 f:\research\research integrity\final documents\2. procedure for the ethical review of research projects - 18_02_2015.docx 9