Research Ethics in European Studies An Official Statement of Research Ethics Policy and Procedures in Cardiff School of European Studies This statement of policy and procedures has been approved by the School Board, the Research Committee, the Post-Graduate Committee and the Politics and Languages Boards of Studies. The procedure has been amended to take into account discussions in these instances, as well as the comments of the University Research Ethics Committee. INDEX Page RESEARCH ETHICS IN THE SCHOOL OF EUROPEAN STUDIES 2 BEING EXPLICIT ABOUT ETHICS 4 THE RESEARCH ETHICS PROPOSAL FORM 5 RESEARCH ETHICS CONSENT FORM FOR ANONYMOUS DATA 6 RESEARCH ETHICS CONSENT FORM FOR CONFIDENTIAL DATA 7 APPENDIX 1: QUESTIONS AND ANSWERS RELATING TO RESEARCH ETHICS 8 APPENDIX 2: ETHICAL APPROVAL OF RESEARCH IN THE SCHOOL 9 OF EUROPEAN STUDIES APPENDIX 3: INFORMATION ON SUBMITTING APPLICATIONS TO THE SCHOOL RESEARCH ETHICS SUB-COMMITTEE 12 1). Research Ethics in the School of European Studies The Cardiff School of European Studies is a dynamic, multi-disciplinary environment. Our research encompasses academic disciplines within the social sciences, arts and humanities and languages. Issues of research ethics vary between these academic disciplines. Our ethical review process reflects this diversity. The School Research Ethics Committee is a sub-committee of the Research Committee. The Ethics sub-committee meets as and when necessary, but no less frequently than once a semester. Research Ethics in the School of European Studies is guided by the principle of subsidiarity: Issues of ethics that concern under-graduate students are dealt with by the Politics and Languages sections. Ethics is a standing item on the agenda of such meetings. Ethical issues are most likely to arise in the connection of the year abroad dissertation. Proposals for the year abroad dissertation must be formally approved by the Boards of Studies before research can be carried out. Proposals should be drafted on the Research Ethics proposal form. Postgraduate ethical issues are deal with by the Post-Graduate Committee. Postgraduate representatives on the committee will not be present when issues of research ethics are being discussed. Proposals should be drafted on the Research Ethics proposal form. Staff projects are considered by the Ethics sub-committee of the Research Committee. Proposals are drafted on the Research Ethics proposal form; copes of proposed correspondence are appended to the proposal form. Our research ethics procedure takes into account the diversity of methodologies that inform our work. In general: No children under the age of 16 are used as participants in research No other vulnerable groups are used as participants. Members of the general public are not involved in research, except occasionally as part of surveys carried out by professional polling organisations. No participants are recruited outside of the University (and no-one is paid for participating in any research in EUROS) We are not involved in research involving mood inductions. We do engage in research that involves interviews and questionnaires. Anonymous elite interviews are conducted by some staff and students in the 2 pursuit of their research. Such projects must obtain ethical approval by the relevant body (Board of Studies, Post-Graduate Committee, or Ethics SubCommittee of the Research Committee). Following the University’s recommendations, the basic rule for research ethics in EUROS ought to be as follows. Where research does not involve living subjects, we have no specific procedures in place. Where the research involves living subjects, our procedure respects established pattern of school governance. In organisational terms the principle of subsidiarity applies: Supervisors and their students (in the case of PGR, PGT, undergraduate dissertations and year-abroad projects) should determine whether projects need to be referred to the relevant committee. Each research project (PhD thesis, MA dissertation, year abroad dissertation) is considered first by the appropriate supervisor. The supervisor considers the proposed project. When it involves either interviews or questionnaires, it needs to be considered by the Board of Studies, Post-Graduate Committee, or Ethics Sub-Committee of the Research Committee, as appropriate. All members of staff must present new research projects for ethical approval to the Ethics Sub-Committee of the Research Committee. This does not mean that every article or book needs to be approved in advance, but it does mean that the discreet research project from which it is drawn needs to have ethical approval. Where should proposals be considered? As a rule of thumb: 1. The Boards of Studies will be used to consider, approve or reject proposed dissertations and year abroad projects. 2. For Post-Graduate projects, each student and their supervisor will determine whether the research requires approval by the ethics process. Where there are no ethical issues, the supervisor needs to indicate this on the existing proforma that accompanies the dissertation. Should student and supervisor decide there are ethical issues (notably where there are interviews or questionnaires), it is their duty to bring the proposal to the attention of the Post-Graduate Committee. Research Ethics will henceforth be a standing item on the Post-Graduate committee and all proposed research needs with ethical implications need to be formally considered and approved by the post-graduate committee. 3. All research proposals involving living individuals by members of staff need to be seen by the School Research Committee, with a view to obtaining the ‘Research ethics approved’ stamp. This is not limited to funded research. Research Ethics will be a standing item on the Research Committee. In the event of a large number of projects being considered, the Research Committee will reconvene as the Research Ethics sub-Committee. Decisions on all research projects need to be minuted. Proposals are submitted on the accompanying form 3 Being Explicit about Ethics Any research bid in EUROS that involves human subjects needs to be explicit about the ethics criteria adopted. What this means in practice depends somewhat upon the type of activity envisaged. The basic criteria are as follows: 1). Interviews. Proposals need to guarantee to respect anonymity and/ or confidentiality. Anonymity is the preferable term. It imples that no individual interviewee is ever cited, unless there is specific written agreement to the contrary. In advance of the bid coming to the Ethics sub-committee of the Research Committee, researchers need to have developed a ‘consent sheet’ along the lines of the pro-forma below. The Committee needs to see an example of a standard letter to be sent out to interviewees. Interviews will be anonymous, unless agreed otherwise. Permission to quote verbatim from an interview will be granted or refused by e.mail receipt or by written communication. Confidentiality implies that material can be retrieved, but that permission will be required. The school will need to guarantee to keep copies of taped interviews within the School for a five-year period. Interview transcriptions or tapes will be provided if requested. Project teams intending to use interviews need to develop an appropriate statement that can be approved by the Committee. We recommend the statement below. 2). Questionnaires. Conditions are somewhat different. In the event of participants accepting to respond to an anonymous questionnaire, their consent is implied, on condition that the covering sheet makes it clear what the questionnaire is intended for and that its findings might be published. Questionnaires will be kept within the School. If they are anonymous, they can not be provided to participants. The questionnaire will contain details of the use to which such information is intended and guarantees of anonymity. 3). Publications are at the heart of the academic enterprise. The main safeguards are those of the standard refereeing process, together with the guarantee of confidentiality and anonymity. In research ethics terms, we need to inform human subjects in writing of likely future publication plans at the same time as their participation in a project is solicited. In the standard letter soliciting an interview, for example, apart from guaranteeing anonymity and/or confidentiality, we need to state that the research will produce a book/article/press article (as appropriate) and ascertain that subjects are happy with this. In the interview itself, university guidelines are that a consent form should be signed before the interviews proceeds. 4 Cardiff School of European Studies Research Ethics Proposal Form Submitted by: Staff UG PG Please circle as appropriate Please attach this form to the front of your Research proposal Researcher’s Name: Supervisor: Project Title: This form should be returned to the section (for undergraduates), the post-graduate committee (for postgraduates) or the Research Committee (staff) well in advance of any research you intend to carry out. Before any new research can be carried out, it needs to have considered the ethical procedures contained in this document. When submitting a research proposal that has ethical implications, please ensure that you have included copies of the necessary informed consent forms, if your research is dealing with living data. Any new research project (which might produce distinct books, articles or other form of published output) undertaken by members of staff ought to be submitted even if it does not have ethical considerations. Action Agreement I have consulted the School’s Research Ethics Policy on the website I enclose a copy of my proposed letter to interviewees that sets out the nature of their participation in the research project (if applicable) I have consulted the Year Abroad ethics procedure (if applicable) I enclose a copy of the Consent Form addressed to interviewees (if applicable) The proposal has been checked by my supervisor (if applicable) 5 Research Ethics Consent Form for Anonymous data This template needs to be adapted to the individual circumstances of the research project I understand that my participation in this project will involve [provide brief description of what is required, eg ...completing two questionnaires about my attitudes toward controversial issues which will require approximately 20 minutes of my time.]. I understand that participation in this study is entirely voluntary and that I can withdraw from the study at any time without giving a reason and without loss of payment (or course credit). I understand that I am free to ask any questions at any time. If for any reason I experience discomfort during participation in this project, I am free to withdraw. I understand that the information provided by me will be held totally anonymously, so that it is impossible to trace this information back to me individually. I understand that, in accordance with the Data Protection Act, this information may be retained indefinitely. I.___________________________________ (NAME) consent to participate in the study conducted by [name of individual] School of European Studies, Cardiff University with the supervision of [name of supervisor if appropriate]. Signed: Date: 6 Research Ethics Consent Form for Confidential data This template needs to be adapted to the individual circumstances of the research project I understand that my participation in this project will involve [provide brief description of what is required, eg ...completing two questionnaires about my attitudes toward controversial issues which will require approximately 20 minutes of my time.]. I understand that participation in this study is entirely voluntary and that I can withdraw from the study at any time without giving a reason. I understand that I am free to ask any questions at any time. If for any reason I experience discomfort during participation in this project, I am free to withdraw. I understand that the information provided by me will be held confidentially, such that only [name(s) of researchers where applicable] can trace this information back to me individually. The information will be retained for up to five years when it will be deleted/destroyed. I understand that I can ask for the information I provide to be deleted/destroyed at any time and, in accordance with the Data Protection Act, I can have access to the information at any time. I, __________________________________ (NAME) consent to participate in the study conducted by [name of student] School of European Studies, Cardiff University with the supervision of [name of supervisor}. Signed: Date: 7 Appendix 1: Questions and Answers Relating to Research Ethics Q). I am a member of staff and I want to start a new project that involves interviews. What do I have to do? A). Any new research project needs to be approved by the Research Committee ors its ethics sub-committee. You must fill out the Proposal Form and present this to the Research Committee, which will decide whether the work has ethical implications. You must also present either a Confidential Data or an Anonymous Data Consent Form, as well as a covering letter-template to interviewees Q). I am an undergraduate student going on my year abroad. What do I need to do? A). First of all, consult the Year Abroad guidelines. Before starting any research for your year abroad project, you must draw up a proposal. If this involves interviewing anybody, it must be approved by the Board of Studies. Proposals can be considered while students are on their year abroad. Q). I am an undergraduate student writing a dissertation. What do I do? A). Go and speak first to your supervisor. If your work involves human subjects, you must fill out the Proposal Form and present this to the Board of Studies meeting. You must also present either a Confidential Data or an Anonymous Data Consent Form, as well as a covering letter-template to interviewees Q). I am a postgraduate student writing a dissertation. What do I do? A). First of all you meet with your dissertation supervisor. If your work involves human subjects, you must fill out the Proposal Form and present this to the Board of Studies meeting. You must also present either a Confidential Data or an Anonymous Data Consent Form, as well as a covering letter-template to interviewees Q). I am a PhD student. What do I have to do. A). First of all you meet with your PhD supervisor. If your work involves human subjects, you must fill out the Proposal Form and present this to the Board of Studies meeting. You must also present either a Confidential Data or an Anonymous Data Consent Form, as well as a covering letter-template to interviewees. 8 Appendix 2 Ethical Approval of Research in the School of European Studies The School of European Studies has designated a School Ethics Officer responsible for the management of ethical issues in research in the School. The responsibilities of the School Ethics Officer are as follows: (a) ensuring that there are effective mechanisms to bring any policy, guidelines or procedures developed with or through the University Research Ethics Committee and the School Research Ethics sub-Committee to the attention of staff and students for whom the School is responsible. These mechanisms are intended to clarify that it is a University requirement that these policies, guidelines and procedures are followed (b) keeping School ethical issues in research under review (c) managing and monitoring the procedures in practice (d) ensuring that appropriate records of applications, practices and decisions are made and kept (e) reporting to the Head of School as appropriate (f) reporting to the School through an appropriate forum (g) reporting on an annual basis on behalf of the School to the University Research Ethics Committee (h) conducting a three yearly review of School ethical procedures and reporting the outcome to the University Research Ethics Committee; (i) being eligible for membership of the University Research Ethics Committee which entails attending meetings of the University Research Ethics Committee and dealing with the work of that Committee. The School Ethics Officer is Professor Alistair Cole (ColeA@Cardiff.ac.uk) SCHOOL RESEARCH ETHICS SUB-COMMITTEE The School Research Ethics sub- Committee meets, as appropriate, as a meeting of the School Research Committee. The composition of the committee is the same as the latter. Terms of Reference The School Research Ethics Committee's terms of reference are: 9 (a) to consider non-clinical research proposals (from both the School’s staff and its students) involving human participants, human material or human data (b) to either give written approval for such proposals in the form of minutes or provide written information as to why approval has not been given (c) to consider revised submissions (d) to refer to the University Research Ethics Committee cases which cannot be satisfactorily resolved or about which there is uncertainty Application Procedure The procedures for considering these ethical issues are as follows: Research proposals involving human participants, human material or human data are submitted to the Boards of Studies (undergraduates). Post-Graduate Committee (postgraduates) or Research Committee (staff). The Research Committee may decide to convene in special session as the Research Ethics sub- Committee. The Cardiff School of European Studies Research Ethics Proposal Form should be used for all submissions. In the case of proposals involving an externally-funded contract or sponsorship, the applicant will be required to bring to the attention of the SREC if academic freedom and public rights are restricted in any agreement. It will be necessary for the SREC to decide whether the restrictions are acceptable or not. The School Research Ethics sub-Committee will inform the applicant of the decision and any amendments that need to be made or reasons for not approving the research. If the research application has not been approved by the School Research Ethics Committee the applicant may make an appeal concerning this decision through the School Research Ethics Committee to the University Research Ethics Committee. The University Research Ethics Committee hearing the application, either as the initial review body or on appeal, will follow the procedures set out in the document ‘Constitution and Operation of the University Research Ethics Committee’. Timing of the School Research Ethics Committee Meetings The School Research Ethics sub-committee meets when convoked by the School Ethics Officer. Research Ethics is a standing item on the Research Committee agenda. 10 Timing of application of submissions to the School Research Ethics Committee Applications needs to be tabled by the Friday 12.00 preceeding the School Research Committee (meeting the second Wednesday of every month). Procedures (if any) to deal with applications between meetings. In exceptional circumstances, chair’s action might be necessary. 11 Appendix Three Information on Submitting Applications to the School Research Ethics sub-committee Before you can start any research project involving human participants, human material or human data in the School, you have to obtain formal approval from the School Research Committee (for staff), the Post-Graduate (for post-graduate students), the Politics or Languages Board of Studies (for undergraduates). These Committees receive research proposals from students and staff of the School and to consider any ethical issues that might arise from carrying out this research. We can make three main kinds of decision on the proposal. Either the project is approved as it stands, or it is accepted subject to specified alterations, or it is rejected. You will receive a letter or an e.mail as soon as possible after a decision has been made telling you what we have decided and (if relevant) why we have made the decision and what you now have to do. Please note, if your project is approved subject to specified alterations, you may NOT proceed to start the research until these changes have been approved by the Convenor/Chair of the School Research Ethics Committee. In all cases (whether your submission is approved immediately or following revisions), please make sure you retain your Ethical approval letter. You will be asked to include it with your project (not in the form of an Appendix, but loose inside the front cover, so that it can be checked for approval, and then removed to ensure anonymity for the marking phase). All undergraduates and postgraduate students must get formal approval before starting any relevant research work. Staff must also submit their own research plans for ethical consideration, whether the work is funded or unfunded, if the research is being carried out in their capacity as members of University staff or using University facilities. The University policy of review of non-clinical research applies to everyone carrying out research for the University including all University employees, whether their current place of work is within or outside University premises. It also applies to all visiting researchers of the University whether or not they are employed by the University, including persons with honorary positions, conducting research within, or on behalf of, the University. Criteria for determining Research Ethics Working with people We want to know that the safety and wellbeing of research participants is assured, that the applicant is aware of any possible ethical issues in carrying out the research and that steps have been taken to ensure that best practice is followed. It is very important that people are aware that you respect their confidentiality and that, where possible, rigorous steps will be taken to preserve anonymity. 12 Recruiting participants The doctrine of valid consent operates here. That is, participants should enter into the research freely and willingly and know and understand what they are agreeing to when they take part. They should be told they have the right to withdraw from the research at any time. Wherever possible, anonymity and confidentiality should be maintained. Electronic Recruiting On the question of recruiting participants via e-mail and the Web (‘electronic recruiting’) we have decided that (a) in principle we see no reason to veto this method; (b) we anticipate potential problems where the computer network would be overloaded; (c) the number of electronic recruiting proposals should be carefully monitored. Electronic recruiting is acceptable within the following limitations: - Any mailing to an identifiable group of people (e.g. to all of the students in a School or a class) should be brief and succinctly explain the nature of the research and the criteria for participation. - Clear indication that this is a request for help from a researcher should be given at the beginning and that the reader, if not interested, should ‘hit the delete button’. - If the reader of the e-mail is interested in participating then he or she should be asked to contact the researcher directly (not a group reply), or referred to a Web page where the research information is located. - Under no circumstances should University Office telephone numbers be given as contacts for student research. Under no circumstances should file attachments to group messages be used. - The Cardiff University Information Services Postmaster must be asked for permission to send e-mails to group addresses. As well as complying with data protection principles this will also provide a means of monitoring the use of email across campus for research of this kind. The researcher should check that they are complying with data protection principles in the use of personal information. Issues to Consider when Providing Information to Potential Participants It is essential to explain what you are asking people to do and the possible implications so that they can make a proper decision for themselves whether they wish to take part. You must clearly explain the following matters in terms that an ordinary person, rather than a specialist in your field, can understand: 13 - that you are inviting them to take part in a research project - who you are – a student/your post in the University and, where relevant, your experience in conducting research of this kind - the nature, risks (if any), benefits (if any), duration and purpose of the research project. This must include clear information about what the participant will be asked to do, where the research will be carried out, any risks to the participant’s health and safety and the steps that will be taken to minimise those risks - that participation in the project is entirely voluntary - if the project is funded (and if so, by whom) - if the research project is part of a student’s coursework - what the information gathered is intended to be used for, including whether it is intended to publish the results - the arrangements concerning confidentiality of, and access to, information about the research participant - how the research participant can obtain further information about the project (such as by the provision of work contact numbers/email for the researcher; home contact numbers should not be given nor should university office numbers be given where the researcher is a student.) - who the research participant can contact if they are concerned about any aspect of how the research was conducted. This would normally be the Convenor/Chair of the School Research Ethics sub-Committee If participation in a research project is likely to be of no direct benefit to the participants, you should explain this in the information sheet You should give the research participant a copy of the information sheet to keep. Consent Forms It would normally be expected that proposed research participants would be asked to give their agreement in writing on a consent form. Ideally, the information sheet should be separate from the consent form and the School Research Ethics subCommittee will wish to receive a copy of both. You should ensure that, before written consent is given, the proposed participant has been given the opportunity of reading the information sheet and asking questions about the research. For this reason, sufficient time must be provided between the request to take part and the signing of the document. Participant’s signatures do not normally need to be witnessed. 14 Exceptionally, it may be unnecessary or inappropriate to seek written consent although this will need to be clearly justified to the School Research Ethics subCommittee. For example, in cases where you are, for example, handing out questionnaires that do not ask probing questions and it is clear from the front sheet what is going to be asked then we can assume that the act of accepting the questionnaire implies consent by the respondent. There may be other situations too where provision of an information sheet would be sufficient. Where, for good reason, written consent is not sought, you must still ensure that you give proposed research participants sufficient time to read the information about the research and ask questions. In most cases however, you will have to supply the Committee with a consent form. Confidentiality of information obtained during research You must familiarise yourself and comply with current legal requirements for storage of and access to data about research participants. You must consider the method of keeping personal data about research participants and how to anonymise information about them, where appropriate. What happens if I want to publish the research? There are ethical issues involved in respect of publishing research. You must tell the proposed research participant in advance if you have any intention of publishing the results of the project. You must also explain the extent to which, if at all, any identifying information about the research participant will appear in the publication. If identifying information about the research participant is intended to be published, you must obtain and keep specific written agreement to this from the research participant. Preferably these issues should be addressed in the information sheet and consent form that are given out before the research starts. This will prevent any disappointment if the individual, when asked later, chooses not to agree and therefore reduces the value of the information that can be published. In most cases you will not be the only person with an interest in publishing the results. Research is a collaborative activity and, in the case of student work, supervisors may expect to claim some contribution. Informing Research Participants of the Results of Research You are encouraged to consider the issue of informing research participants of the results of the research or where they may be able to get access to this information, although research participants may not be able to be given their individual results. Taking part in non-clinical research is a voluntary matter requiring good-will on the part of the community and it is appropriate for research participants to be able to receive feedback on research they have been involved in where this is possible. 15 Making an application to the bodies dealing with Research Ethics There are five stages in preparing an application to the Research Ethics Committee. These are: 1. Discuss any ethical issues you have about the conduct of your research with your co-investigator(s) and/or supervisor(s). 2. Prepare your submission. Use the proforma provided by School for your submission. 3. Append ALL required documents. 4. Sign and date the form and ask any co-investigator/supervisor to sign. Unsigned submissions will not be considered. 5. Submit [TWO] copies of your application in time for the deadline for the next meeting of the bodies dealing with Research Ethics. Late submissions Please note that submissions that are received late will NOT be considered until the next meeting of the Committee, save in exceptional circumstances. It is the applicant’s responsibility to submit applications in good time and in the proper format. It is the responsibility of a student’s first named supervisor to draw the student’s attention to these procedures. Powers of the School Research Ethics Committee (and associated bodies as detailed above) The Committee (s) may: authorise the research to proceed without requiring any amendment. Any such authorisation is granted on the basis of the project proceeding exactly as stated on the research submission. Any subsequent changes must be notified to the Committee (see below) and renewed approval obtained before proceeding; require clarification or modification of parts of the research submission. The Convenor/Chair will generally be granted the authority to approve the amendments without requiring to call a further meeting of the full Committee; defer consideration of a proposal to a subsequent meeting if substantial modifications are required or where significant additional information is required; reject the research proposal in whole or in part; revoke approval of the research if dissatisfied with the conduct of the research or of the researcher(s); 16 refer university students or staff to the University’s Research Ethics Committee if issues of concern arise from the conduct of the research. As part of their assistance to researchers, the Committee will ordinarily give reasons for requiring modification to proposals, rejecting them or for revoking approval. The Committee may call for reports on the conduct of the research during projects and on completion to help the Committee in formulating its guidance and so that the Committee can be assured that projects continue to conform to approved ethical standards. This will not in any way reduce the responsibility of the researcher to ensure such conformity. The Committee will maintain a record of all proposed research projects, and may require a formal report on completion of the project in order to review the outcome of the research and its contribution to knowledge. Appeals If you are dissatisfied with the decision made by the School Research Ethics sub-Committee (or the body serving in that capacity) you should in the first instance discuss this with the School Ethics Officer. If discussion is unable to resolve the issue satisfactorily an appeal against the decision of the School Research Ethics Committee may be made to the University Research Ethics Committee via the School Ethics Committee and the Head of School. However, it should be noted that the University Research Ethics Committee will not normally interfere with a School Research Ethics Committee decision to require revisions to the project, such as to amend an information sheet or consent form. The University Research Ethics Committee is concerned only with the general principles of natural justice, reasonableness and fairness of the decision made by the School Research Ethics Committee. 17 18