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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: 
Cancer Councl Victoria
Specific comments
Specific 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?: 
The new approach to the Code, encompassing a principles-based document supported by guides that provide specific advice on implementation, is appropriate and provides comprehensive coverage of the many issues involved. The Code is very clear and the principles-based approach is a helpful development.
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?: 
As a high-level document, the draft Code is suitably broad to cover research principles across all research disciplines. It does not seem to favour specific disciplines, and allows for the development of more specific discipline-based guidance to be developed to align with it.
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.: 
The shift in approach from breaches of the Code and research misconduct, to only using the term breaches is clearly articulated in the Guide. This allows for institutions to have some flexibility in deciding which terms they will use to implement their policies. There may be some confusion if a breach involving multiple institutions is assessed under policies using the different terminologies.
Question 4: Do you think the process described for investigating and managing potential breaches of the Code is clearly described and practical?: 
The process for investigating and managing potential breaches of the Code is clearly described and appears practical. The flowchart showing the overview of the process (Fig 2 in the Guide) provides a good template for institutions to map out their own processes. The Guide as a whole provides a clearly stepped out process for managing and investigating complaints. The checklists are a particularly useful initiative in assisting institutions to manage the process.
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.: 
Yes, case studies would offer insight into how different breaches could be managed, and would be a useful resource not only when considering how to manage potential breaches, but also in developing and delivering research integrity training to staff and researchers.
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?: 
Section 7.6 notes that institutions should have an appeals process, and that ARIC provides a review system for institutions in receipt of NHMRC or ARC funding. It should be clarified if ARIC is required to handle appeals for these institutions, or if this is just one option open to institutions funded by these bodies. More information on when a person subject to a complaint can appeal to a higher authority, such as the courts, would also be useful.
Question 7: Please comment on which three topics you would nominate as being the highest priority and why.: 
All of the listed topics for additional guides to support implementation of the new Code are important. The three topics which would be of highest priority are: 1) supervision - many problems in research are caused by unsatisfactory supervision and failure of supervisors to understand their responsibilities; 2) conflicts of interest - the need to spell out what constitutes a conflict of interest and the impact that unrecognised conflict may have on opinions and conclusions in research reports; and 3) intellectual property - intellectual property is becoming an increasingly important and breaches occur, some by senior researchers, some by more junior researchers who perhaps may have failed to understand its importance.

Page reviewed: 17 September, 2018