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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: 
Deakin University
Specific comments
Specific comments: 
Preamble in Code

Deakin University strongly supports the proposed changes, especially as they relate to:

  • the principles-based approach
  • the concision of the Code in describing key principles and responsibilities for responsible research conduct for both researchers and institutions
  • the introduction of better practice guides that provide the specifics of an aspect or element of the Code
  • the continuing inclusion of the role of the Research Integrity Advisors
  • the replacement of the term ‘research misconduct’ with the expanded concept of research integrity breach.


The principles and responsibilities for responsible research conduct are very clear.
Deakin University suggests that the principles and responsibilities in the new Code not only underpin the trustworthiness of research, but also the excellence of research being carried out by an institution. Deakin proposes that more emphasis is given to why these principles and responsibilities are important, both from an individual point of view and from the view of the institution, and to facilitate researcher understanding of why they need to uphold them.


Significant change to the framework for addressing potential breaches of research integrity is welcome and important. The principles and responsibilities of institutions are clearly defined. Deakin University is of the opinion that the removal of the term ‘research misconduct’ and the expansion of ‘research integrity breach’ concept as described in the draft Code better accommodates the diverse and sometimes discipline-specific departures from research integrity that are observed. This less rigid framework better enables academic judgement in the consideration of potential breaches. It also provides impetus for institutions and the academy to address practices that would not be considered research misconduct, but that are relatively frequent, such as poor data management. In this way, the proposed Code is similar to the Canadian Tri-Agencies Responsible Conduct of Research Framework, which is a policy that has been successful in addressing the spectrum of departures from research integrity. There is also the opportunity for the revised Code to be a useful tool for negotiation of future enterprise agreements, encouraging institutions to promote a research culture and an environment that supports researchers in the responsible and ethical conduct of research, as opposed to a regular monitoring of the institution’s performance with regard to the Code.


The draft Code and Guide provide prominent recognition for the role of Research Integrity Advisors (RIAs) at institutions and operational areas that facilitate responsible research. Deakin University notes, however, that unlike the current Code, it is not a requirement of the draft Code for an institution to establish RIAs. Deakin suggests that the requirement for the establishment and training of RIAs by institutions is a foundational component of research integrity in Australia and should remain compulsory.     


The proposed framework of the Code and an array of supporting guides is supported. In concert with the Code, the 'Guide to investigating and managing potential breaches of the Australian Code for the Responsible Conduct of Research' allows there to be more discretion given to institutions in relation to how they determine what is a minor or major breach and the processes applied to address potential breaches. It clearly describes institutional responsibilities and a role for RIAs. Importantly, it provides a basis for procedural fairness through initial investigation via panel hearings and clarity around the application of ‘balance of probabilities’. Further guides on more specific areas such as supervision, intellectual property, conflict of interest and collaborative research will be very helpful.

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?: 
Deakin University believes that the approach adopted by the draft code is excellent. The principles-based approach will assist in ensuring broad knowledge of the rationale, as well as the responsibilities of institutions and researchers. It will facilitate shared understanding among research managers, advisors and researchers/research teams. Deakin University is of the opinion that further improvement of the reasons for the principles will be of benefit in explaining the rationale.
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?: 
Deakin University believes that the draft Code captures expectations across all disciplines. The draft has been reviewed by animal, human and biosafety researchers, as well as those conducting research that does not involve any of those areas. The use of general language in the document ensures its broad relevance to research within all disciplines.
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.: 
It is the view of Deakin University that this guidance is clear and implementable. The new terminology of 'breaches' of the Code captures 'misconduct', using the word from the previous terminology, whilst providing discretion for institutions and researchers to address cases of research lapses. As described above, there are advantages to the 'breach' approach in addressing departures from research integrity that have occurred by honest error rather than by intent or recklessness. The table that distinguishes between minor and major breaches is helpful. The approach will potentially result in an increased interface between the Code and the regulation breaches in human research ethics and animal care and use. This may result in increased administrative burden for research ethics committees and reporting. In addition, it may result in an increased shared understanding of the responsible conduct of research and the mechanisms by which research ethics committees can address non-compliance.
Question 4: Do you think the process described for investigating and managing potential breaches of the Code is clearly described and practical?: 
Section 4 outlines a comprehensive process while allowing discretion at the institutional level to investigate any potential breaches and, as required, take corrective and preventative steps to avoid the repetition of the breach. The flow chart will be very helpful, and the description of the process itself is both thorough and specific.
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.: 
Realistic case studies could assist researchers understanding of expectations and assist institutions in making determinations in cases of potential breach(es). In addition, such case studies could prove useful as part of training in the Code provided by institutions. Researchers may well reflect on past practice and consider different future options when undertaking their respective research projects.
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 overview of the appeal process described in Section 7.6 regarding the requirement to provide a process of appeal against judgments of a breach is clear. At the same time, its general nature leaves it to the institution to determine the specifics of that appeal process.
Question 7: Please comment on which three topics you would nominate as being the highest priority and why.: 
From the Deakin University perspective, the three highest priority areas are supervision, collaborative research, and intellectual property. • Supervision: Supervisor practice in relation to student supervision has traditionally been a matter of individual style, there is variability in practices and variability in supervisor knowledge of, and attention to, broader issues of the professional development of student researchers beyond thesis project management. At Deakin, we have had supervisor training in place for several years and, for the past year, required triennial certification of supervisors. Our effort is aimed at promoting close supervision. Even so, it is Deakin's view that a guideline on supervision that specifies what is expected of supervisors in terms of acceptable practice would be very helpful to institutions, researchers and student researchers. • Collaborative research: Collaborative research involving partners from other Australian universities, research institutions and industry is likely to involve a requirement to deal with differences in how research conduct and breaches to the Code are managed, even when both/all are working within the same Code. Collaborations with non-Australian universities and research institutions will involve a need to be compliant across multiple codes. The complexity of this set of conditions together with the relative lack of knowledge on the part of researchers suggests to us the need for a guideline in this area. • Intellectual Property: This is poorly understood by researchers generally in our experience. What constitutes intellectual property, who owns it and what is the ethically correct way of managing it could all be improved by production of a guideline document. Although not requested, other possible guidelines which would be helpful are: • Conflicts of Interest: Conflicts of Interest exist throughout research, from peer review to the commercialisation of research findings. The identification, disclosure and management of Conflicts of Interest is fundamentally important for trust in research. Furthermore, increased guidance for researchers and institutions in this area would help build trust between the academy and industry. This is likely to support innovation and the translation of basic research outputs into the market. • Research Integrity Advisors – RIAs are an important Australian invention for research integrity. A better practice guide that describes establishing, recruiting, training and supporting a network of RIAs would be of benefit to research communities at small and large institutions.

Page reviewed: 17 September, 2018