TSL Policy on Scientific Integrity
The Sainsbury Laboratory (TSL) has a responsibility to ensure that the funds it disperses are properly spent, in accordance with the law, funder requirements and in the public interest. Researchers have a duty to their profession, to the public, to TSL and to research funders, to conduct their research according to best scientific practice and the highest professional standards.
Research misconduct (as defined below) is least likely to arise in an environment where the adoption of professional standards and the principles of good practice are required and where appropriate managerial systems are in place to provide support and oversight. TSL is committed to the maintenance of such an environment through the provision of this policy and through supervision at all levels to ensure good research practice is adhered to at all times.
Who this policy applies to
This policy applies to all staff working at TSL, including but not limited to: research, support and administrative staff employed by the Laboratory; staff employed on grants or short-term contracts; and students.
The term ‘research’ as used here refers to all aspects of the research process, including but not limited to: applications for funding; the formulation of a hypothesis; the designing of experimental protocols; the performance of experiments and the generation of data; the recording, analysis, publication and archiving of data; the preparation and publication of experimental designs, data and conclusions; the communication of research to colleagues and the wider community; and the use of experimental organisms and materials.
TSL researchers must adhere to the following standards of professional conduct at all times:
- Honesty and fairness: TSL scientists should be honest when reporting on their research, particularly concerning how it is conducted and reported, its potential implications, and in acknowledging the work of others.
- Accuracy and rigour: in conducting, reporting and publishing research, clarifying what the data and conclusions are based on, where they were derived from, and how they can be verified. Proper record keeping of the primary data is essential, as is the fair representation of individual contributions.
- Accountability to funders and the general public.
- Openness and transparency: Researchers should have no other interest beyond the scientific and should always be willing and able to account for their actions. Researchers should always be prepared to communicate, analyse, report and question the outcome of their research and to disclose any conflicts of interest.
- Independence: Researchers are expected to conduct their research with independence and impartiality, in keeping with the environment of academic freedom they work in. Researchers should not interfere with the independence of their colleagues or team members.
- Respect for colleagues and for experimental organisms and subjects, including compliance with relevant research ethics policies and requirements.
- Co-operation and collegiality in scientific interactions and communications, and in the sharing of resources.
DEFINITION OF RESEARCH MISCONDUCT
TSL researchers are expected to observe the highest standards of professional conduct in the proposing, conducting and reporting of research. Any practice or conduct that deviates from ethical and professional standards for these activities constitutes misconduct.
Research misconduct includes, but is not limited to:
- Mis-representation, falsification or fabrication of data, including fraud – intentionally misleading or deliberately false reporting of information.
- Unacknowledged appropriation of other’s work, including plagiarism, piracy, the abuse of confidentiality with respect to unpublished materials, or misappropriation of results, materials or other resources.
- Conduct that contravenes the standards expected by TSL or other relevant bodies, and that deviates from accepted ethical and professional standards in research.
- Failure to follow accepted procedures or to exercise due care in avoiding unreasonable risk of harm to colleagues or research subjects or organisms.
- Mismanagement or inadequate preservation of data and primary materials, as outlined in the guidelines below.
- Inappropriate conduct in peer review, including failure to disclose conflicts of interest, disregard of the requirement for confidentiality, or the misuse of data for personal advantage.
- Misrepresentation of involvement or authorship.
- Improper dealing with allegations of misconduct.
Research misconduct does not include honest error, or honest differences in the interpretation or assessment of data.
However, once an error is detected it is the researcher’s responsibility to address the issue and fix the record in a timely fashion. Failure to do so could be construed as research misconduct.
PRINCIPLES OF GOOD RESEARCH PRACTICE
- A Critical Approach
Researchers should always be prepared to question the outcome of their research. TSL expects all research results to be checked by Research Group Leaders before being made public. It is important that research can be challenged and tested once published.
Researchers should not become subject to other pressures such that the normal processes of research inquiry cannot be enforced, e.g. via their Group Leader or by constraints imposed by the source of funding of the research. Pressure to produce results that suit the specific interests of a funder must be resisted. This is particularly the case where researchers could be perceived to have a conflict of interest, e.g. where they might have an equity share in the funder or may hold a position with or be involved in consultancy with the funder. Any such conflict of interest, whether real, potential or perceived, should be disclosed at the earliest opportunity to the Head of Administration.
- Documenting Results
Throughout their work, researchers should keep clear and accurate records, in English, of the procedures they have followed, the sources of research material, where archives or collections are located and of the results obtained, including interim results. This is necessary not only as a means of demonstrating proper research practice, but also for effectively responding to questions and concerns, for example, about how research has been conducted, about the results obtained, and about the ownership of the data or results. The proper documentation of lab work and the correct archiving of raw data (see point below) will minimise instances where essential information required for dealing with allegations of research misconduct, such as the original data, have allegedly been lost or cannot be replicated.
- Storage and Disposal of Data
Primary data that forms the basis of published work should be securely stored for at least 10 years in a durable form, and in accordance with funder requirements. The means of data storage should be appropriate to the task. Provision should be made for the automatic back-up of data or software stored on a computer or other internal storage system with an automatic back up facility. Special attention should be paid to guaranteeing the security of electronic data. Responsibility for provision of appropriate backup facilities lies with the Laboratory, and it is the responsibility of researchers to use these facilities to ensure all data is appropriately backed up and stored securely.
- Authorship and Publication
Authorship is important in the context of good research practice. Authors are generally defined as individuals who have made substantial contributions to the conception or design of the work, and to the acquisition, analysis, or interpretation of data for it; they also contribute to drafting and revising the article for its intellectual content and must approve its final version for publication. Authors must therefore be familiar with the content of the published article and be accountable for all aspects of the work, and for ensuring that questions relating to the accuracy or integrity of any part of the work are appropriately responded to, investigated and resolved.
It is critical that Group Leaders appreciate the importance of authorship to their team members and coauthors. Authorship is the primary currency of productivity in science and it can dramatically impact a researcher’s career. Therefore, senior/corresponding authors should ensure that authorship and author ranking is distributed in a fair and transparent manner. Pre-arranged authorship deals, e.g. when a team member is promised first authorship prior to the completion of the experiments, should not be made. Conversely, team members should appreciate the importance of authorship to their peers and should not aggressively and unfairly lobby their Group Leader for a position that doesn’t reflect their contribution relative to their colleagues.
If a researcher at the Institute is informed of, or discovers themselves, errors in a published article that they have co-authored that diminish the reliability of the published results or the key conclusions drawn, they must discuss this with the lead investigator of the paper and notify promptly any co-authors and the journal concerned. A rapid correction to the published work should be sought, either in the form of a published correction or a retraction, depending on the circumstances involved.
On discovery of any error, a researcher must always inform the Executive Director and Head of Administration as soon as possible.
- Collaborators and Partners
Any person who participates in a substantial way in conceiving, executing or interpreting a significant part of the relevant research should be given the opportunity to be included as an author of a publication that derives from that research. The practice of honorary authorship is unacceptable – only those who have participated in the research should be listed as an author. The contributions of formal collaborators and all others who directly assist or indirectly support the research should also be properly acknowledged. This applies to any circumstances in which statements about the research are made, including provision of information about the nature and process of the research, and in publishing the outcome. Where appropriate, the funders of the research and other collaborating bodies should be acknowledged.
- Exploitation and Protection of Intellectual Assets
Exploiting intellectual property (IP) generated by research is important both to improve economic competitiveness and to generate revenue. The potential to exploit IP should be considered at the application and contract stages, or in discussion with industry partners, and before data are submitted for publication or presented in any other public forum, including the internet. Final decisions on patent inventorship are made by a patent lawyer, but the contribution of all potential inventors should be brought to the attention of the lawyer so that a fair judgement can be made. Where the publication of a piece of work has financial implications, such as a patent application, this must always be disclosed in a competing interest statement on submission of the work for publication.
INSTITUTE SUPPORT AND OVERSIGHT
Support and oversight are two key responsibilities held by TSL in support of research integrity. In recognition of this, the Laboratory provides training and oversight to all employees in the following ways.
Training on Research Integrity
TSL provides regular workshops for Laboratory staff at all levels to train them on key aspects of research integrity and publishing ethics. These workshops are hosted by an external consultant and are run at least twice per year at the Laboratory
All newly-appointed scientific members of TSL are required to attend these workshops during their first year of employment at the Laboratory. Non-attendance may result in the implementation of sanctions by Group Leaders.
TSL oversight of good practice
The Laboratory expects that published papers will have been subject to internal review by Research Group Leaders prior to their submission. TSL operates an internal and regular oversight process, whereby papers submitted by institute researchers are randomly selected during each trimester. The authors of these papers are then required to provide the original supporting data to senior Laboratory staff within a given time so that a judgement can be made on the robustness and integrity of the submitted manuscript.
This process is restricted to original data generated at TSL. In the case of papers published in collaboration with other organisations, TSL encourages collaborators to share their primary data in the interests of rigour and transparency. Collaborators who chose to share data as part of this process should be aware that any data lodged with TSL may, in some instances, be released under the Freedom of Information Act.
This process follows the ‘3:3:3 system’ whereby 3 figures from 3 manuscripts (submitted, under review, under revision, or in press) are randomly selected at 3-monthly intervals for evaluation by an external evaluator.
The evaluator will present the results of the review to the Executive Director and Group Leaders for agreement on one of the following courses of action:
- There is no case to answer.
- The evaluator assesses that there is a case to answer, but the majority view of the Director and Group Leaders is that there is no evidence of wrong-doing.
- The evaluator assesses that there is a case to answer, and the majority view of the Director and Group Leaders is in agreement – in which case the evaluator will present a ‘yellow warning’ to the Group Leader concerned. Yellow warnings will be recorded and recurrence of a ‘yellow warning’ for an individual group will have consequences, with the Chair of Directors and SAB Chair being informed by the Executive Director.
- The evaluator and Executive Director agree that the case is sufficiently serious to be considered further, in which case the procedure for investigating allegations of research misconduct (see below) will be invoked.
PROCEDURE FOR REPORTING ALLEGATIONS OF RESEARCH MISCONDUCT
TSL is committed to upholding the most rigorous standards of good conduct to ensure that the highest-quality research is conducted at and published by researchers at the Laboratory. It will not condone any form of malpractice in the workplace and is committed to creating a safe, fair and honest working environment within the framework of the public disclosure act
No one who raises a genuine concern about malpractice will be at risk of losing their job or suffering any form of retribution or detriment as a result of doing so including harassment or victimisation from another employee.
TSL’s policy on reporting allegations of research misconduct encourages and enables employees to speak out when they encounter or suspect malpractice. This is supported by a public interest disclosure (whistleblowing) policy for the anonymous reporting of such allegations.
In all cases due regard will be given to the need:
- to protect researchers against malicious, frivolous or ill-founded allegations of misconduct in research
- to protect the position and reputation of those alleged to have engaged in misconduct in research when such allegations are not confirmed
- protect the position and reputation of those who make allegations of misconduct in research in good faith
- to observe the principle of non-detriment – neither the person making the allegation of misconduct in research nor the person against whom such an allegation is made should suffer as a consequence of the fact that a good faith allegation has been made
- to consider the public interest, particularly where issues of health and safety may be relevant
Before taking action
This procedure is designed for the consideration of incidents that concern the scientific conduct of a colleague, in circumstances where the complainant believes that such conduct amounts to a criminal offence, a breach of legal obligation or something likely to endanger health, safety or damage the environment.
It does not cover personal employment-related grievances, which are dealt with under a separate policy.
The policy is not designed to address issues related to UEA-registered students. Any such students based at TSL will be subject to the policies and procedures of the University.
All disclosures are made anonymously via an automatic process. Submitting an anonymous form will trigger an automatic notification, which is sent direct to the Executive Director and Head of Administration. To ensure that there is no undue influence or pressure on the complainant, this process bypasses Group Leaders and ensures confidentiality.
If an employee has a concern about research misconduct as defined above, they can initially seek to resolve the matter informally and in confidence. This can be done at any time by approaching a Research Group Leader, Executive Director or Head of Administration. There will be no record of concerns which are resolved informally.
If any employee believes that the matter is more serious, they can raise it confidentially and anonymously by completing the web form which is accessible from the TSL intranet.
Submission of the web form will send an anonymous email to the Executive Director and Head of Administration. Upon receipt, the procedure described below for investigating allegations of research misconduct will be initiated.
The procedure is outlined below.
PROCEDURE FOR INVESTIGATING ALLEGATIONS OF RESEARCH MISCONDUCT
On receipt of a complaint, the Executive Director will consider the most appropriate course of action, and appoint an independent external evaluator (EE) to conduct an investigation if required. Together the Executive Director and EE will be provided with the stored primary data in order to prepare a full report and decide on the best course of action. Possible outcomes include, but are not restricted to:
- The allegation of scientific misconduct is unfounded, either because it is mistaken, is frivolous or is otherwise without substance, in which case it will be dismissed.
- There is some substance in the allegation of misconduct but that the matter does not warrant a formal investigation. If this is the case, a decision will be taken as to what action is required to remedy the matter.
- There is sufficient substance in the allegation of misconduct to instigate a formal investigation of the complaint. The investigation may result in dismissal or suspension from TSL employment, a written reprimand or the imposition of a range of sanctions.
This is not a definitive list of outcomes and The Executive Director and EE are free to consider any other course of action which they feel appropriate in the circumstances.
Appeal and Subsequent Action
The respondent will, in all cases, have the right of appeal against the findings of the EE. This appeal will be submitted in writing to the TSL Chair of Trustee Directors.
The Chair will consider the appeal and make one of the following judgements:
- the decision is upheld and the appeal rejected
- the decision is amended and an alternative action implemented
- the decision is overturned and the appeal upheld
- The Chair will determine another appropriate course of action
The Chair will notify the decision in writing, normally within 21 working days where possible.
Reporting of Outcomes/ Findings
TSL considers the issue of scientific misconduct to be of the utmost importance. The Head of Administration will present a full record of allegations to the Board of Trustee Directors annually for review and investigations will be documented in minutes of Board meetings and made available to employees via the TSL intranet.