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Review of the Australian Code for the Responsible Conduct of Research Submission

Personal Details
This submission reflects the views of
Organisation Name: 
La Trobe University
Specific comments
Specific comments: 
Principles in Code

To the members of the Code Review Committee (CoRC),

Thank you for your invitation posted on 28 November 2016 to provide feedback on the revised Australian Code for the Responsible Conduct of Research (the Code).  Both academic and professional research support staff of La Trobe University have contributed to the responses which are submitted below for your consideration.  Comments on the key points of consideration are listed in the specific consultation questions and general comments.


Specific consultation questions
Question 1: Do you like the new approach to the Code, namely the principles-based document being supported by several guides that provide advice on implementation?: 
Yes, the outline of responsible research conduct principles are well considered and articulated as are the responsibilities of institutions and researchers. The development of additional guides will be critical to aiding researchers and institutions in how to apply these principles practically. It will also be important for these guides to point directly to other guides – in particular existing codes on authorship, human and animal ethics and any guides developed on data management. While it is absolutely appropriate to acknowledge ATSI communities and individuals, there is no equally explicit acknowledgement of other minority, vulnerable and indigenous communities – both in Australia and overseas. Some broader reference could be included to address this.
Question 2:The draft Code is intended to be used by all research disciplines. Do the principles adequately capture the expectations for responsible research across all research disciplines?: 
Yes, although the definition of ‘institutions’ in the Code may need to be expanded to ensure it includes non-government organisations, such as charitable organisations which also conduct research. It would also be good to see a few more examples of what the Code deems as research.
Question 3: The draft Guide refers to breaches of the Code rather than providing a definition of research misconduct, and states that institutions can decide whether or not to use the term research misconduct in their own processes.: 
A potential concern is that interpretation of what constitutes as a breach could vary both across and within institutions, or that the implementation of the Code could be challenged legally. Training, mentoring and experience in the application of the Code ought to reduce the potential for challenges. The approach used in the revised Code is preferable to providing a fixed definition which fails to capture nuances. The clarification that breaches occur on a spectrum is a very important concept to include.
Question 4: Do you think the process described for investigating and managing potential breaches of the Code is clearly described and practical?: 
Yes, it provides a template against which institutions can operationalize the process. There should be clearer advice on the rights of an institution to determine how best to manage preliminary assessments involving minor complaints or concern, and to determine corrective actions. It may not be appropriate to raise all concerns with a Designated Officer (DO), if this person is a very senior member of an institution. Some preliminary assessments could be overseen by ethics/biosafety committees or professional staff within a Research Integrity team and reported to a DO. The Guidelines to investigating and managing potential breaches… could offer some advice about the ability of the DO to delegate this authority. Further, the advice on how to conduct a preliminary assessment is too prescriptive in application for addressing minor complaints and concerns which may not warrant the detailed approach outlined in the Guide. Institutions ought to have the right to self-determine what it sees as rigorous and fair. On the higher end of the spectrum where the complaint or concern appears serious, the guidelines for a preliminary assessment seem appropriate.
Question 5: The Code Review Committee and working group are considering what additional resources should be developed to support implementation of the Code and Guide.: 
Case studies would assist in training relevant personnel, and could be a resource for a website. If case study examples are developed, they should reflect a range of research types. The guidelines are more useful if they are kept tight and simple. It would also be useful to include examples of how breaches were pre-empted, especially if addressing minor issues.
Question 6: Are the mechanisms for review of an investigation clearly and correctly described in Section 7.6 of the Guide? If not, where are the inaccuracies?: 
The information in this section seems appropriate.
Question 7: Please comment on which three topics you would nominate as being the highest priority and why.: 
Data management – researchers are struggling to know what is acceptable given the rapid expansion of digital technology, in particular Cloud technology. There is a need to understand how secure the various existing platforms are. This will assist institutions in allocating resources and providing advice. Authorship – disputes and contentions on authorship entitlements continues to be a vexed aspect of research relationships and can take a considerable amount of time to resolve Supervision – As the number of higher degree by research candidates increases, there has been noticeable variation in the extent to which supervisors are aware of their obligations, as well as that of their students. Collaborative research – both within and across institutions.
General comments

Additional comments:

  1. The Code identifies the responsibilities of institutions and individual researchers but does not identify research leaders – College Heads; Research Centre Directors; Supervisors - as a category with special responsibilities – and it seems fitting that some particular responsibilities are noted.
  2. Inclusion of honours students in scopeIt was noted that the definition of researchers in the draft includes honour students. While it is acknowledged that research by honours students, and other coursework students, should be undertaken according to the principles in the Code, the management of any issues that arise in this cohort within an institution usually reflects coursework/research portfolio structures. Graduate research offices sector-wide do not manage honours students and are not resourced to do so and attempting to manage research integrity issues across a complex organisational and governance matrix can be very difficult. Therefore, it is recommended that honours students not be formally included in the scope of the revised Code, but recommends these principles are considered as ‘best practice’ in relation to Honours research and other coursework programs.
  3. Feedback generally highlighted an appreciation of the values-based framing of the Code and the inclusion of references to duplicate publication, misrepresentation to obtain funding and supervision when describing examples of breaches of responsible research.

La Trobe University again thanks the NHMRC, ARC and UA for the opportunity to comment on the draft Code and breach guidelines.  If there are any queries in relation to this submission, please contact researchintegrity@latrobe.edu.au at any time.

Page reviewed: 17 September, 2018