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The London Institute of Banking & Finance (LIBF) Research Ethics Framework (FRE), which sets out principles, processes, and procedures for the approval and conduct of academic research, as well as steps to be taken in cases of suspected academic research misconduct. The FRE applies to all members of LIBF's academic community, including staff and students, and covers topics such as informed consent, independence, conflicts of interest, and ethical approval for research involving human participants and personal data.
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Framework for Academic Research Ethics
1. Purpose of the Academic Research Ethics Framework 1.1 The London Institute of Banking & Finance (LIBF) seeks to develop research and scholarship skills among its learning community of academic staff and students. It does this through a range of means, including introducing research skills training and research-based dissertations or projects into its taught courses at both postgraduate and undergraduate levels and, more generally, through creating an environment in which thought leadership may be undertaken and the findings disseminated among the community and to a wider audience. 1.2 LIBF’s approach to research and scholarship is set out in its Thought Leadership Strategy^1. This Framework for Academic Research Ethics (FRE) should be read in conjunction with that strategy. 1.3 LIBF is committed to ensuring that academic research undertaken under its aegis, whether by staff, students, or visiting faculty, students or other associates, should adhere to the highest ethical standards. To this end, LIBF has approved this FRE, encompassing a set of principles and the associated processes and procedures for the approval and conduct of academic research and the steps to be taken in cases of suspected academic research misconduct. 1.4 The responsibility for fostering a climate conducive to the conduct of ethically-sound research and for supporting the development of the appropriate skills rests with the senior staff within LIBF. 1.5 The responsibility for overseeing the policies and administering the processes related to the FRE rests with LIBF’s Learning & Teaching Committee. 1.6 This FRE applies to academic research undertaken by all members of LIBF’s academic community, whether permanent staff or staff working on a contract-basis. It also applies to all LIBF students. The FRE applies whether the research relates to higher education, financial capability, professional, or regulatory qualifications. 1.7 Research undertaken for non-academic purposes (for example marketing research) is not required to be submitted through this process; however, individuals undertaking such research should familiarise themselves with the relevant codes of practice (for example, the Chartered Association of Business Schools (CABS) Ethics Guide 201 52 , the Market Research (^1) The Thought Leadership Strategy is available on the About Us page of our website. (^2) CABS. (201 5 ). CABS Ethics Guide 201 5. Available at: http://charteredabs.org/wp- content/uploads/2015/06/Ethics-Guide- 2015 - Advice-and-Guidance.pdf [Accessed: 11 May 2020 ].
Society (MRS) Code of Conduct 201 43 ). Staff members are responsible for determining whether their projects constitute ‘research’. 1.8 If any member of staff is in doubt as to whether their project constitutes ‘academic research’, they should consult with the Dean. 1.9 The Framework, and in particular the Academic Research Ethics Principles, are strongly informed by the following sources of guidance: 1.9.1 The Economic and Social Research Council (ESRC) Framework for Research Ethics (FRE)
assessment as part of the ethical approval application, and their supervisor will determine the level of approval required. 3.5 Collection of data prior to receipt of ethical approval (or confirmation that such approval is not required) will be deemed an instance of research misconduct. Ethical approval / confirmation cannot be backdated. Thus, no research should be undertaken prior to such approval / confirmation. Overview of Process 3.6 The Ethical Approval process is managed by the Faculty and overseen by the Learning & Teaching Committee (LTC), with decisions delegated to a small subgroup of the Faculty, the Ethical Approval Group (EAC). Members of LTC may not oversee approval of their own ethical applications. See also Section 4. 3.7 All staff and students undertaking research must complete an ethical approval application form, that includes a research ethics self-assessment checklist, outlines the proposed research and, where relevant, attaches copies of draft information sheets and consent forms^5. Research may fall into one of three categories: No Risk, Low Risk, and High Risk. 3.8 No Risk. Research that draws on publicly available data that are freely obtainable via the internet or from other sources is likely to be classed as ‘no risk research’. Such research may involve analysis of banks’ websites, the data within companies’ annual reports, or their marketing campaigns; data drawn from government or international bodies such as the Office for National Statistics in the UK, or the Bank for International Settlements; and similar data. Such research will normally only require submission to the Programme Team for student projects, and the Dean for staff projects, and details to be held on record until the completion of the project. Research that involves proprietary information, for example analysis of company records, minutes, etc, is unlikely to be considered ‘no risk’. Similarly, any research involving primary data collection is unlikely to be ‘no risk’ (see ESRC 201 5 , p. 5 ). 3.9 Low Risk. Much research involving human participants and most research involving documentary data that does not fall in the ‘no risk’ category will be considered low risk. Such research will normally be subject to a ‘light-touch’ ethical review and approval process (review by a single ‘Ethical Reviewer’, normally the supervisor, for students’ dissertations; or the Dean, for staff research – see below, Section 4). 3.10 For No Risk and Low Risk applications: 3.10.1 All students (postgraduate research or taught, and undergraduates) should send the ethical approval application form to their supervisor. The supervisor will confirm that the research is ‘no risk’ / ‘low risk’ and forward a copy of the form to the designated person in the relevant qualification programme team who is responsible for co-ordinating the authorisation of the ethical approval application forms (eg programme manager). 3.10.2 Members of staff should forward a copy of the ethical approval application form to the Dean. (^5) All forms are available on the Research Policies and Forms page of our website.
3.10.3 Visiting research staff should forward a copy of the ethical approval application form to their LIBF supervisor or mentor. This individual will confirm that the research is ‘no risk’ / ‘low risk’ and forward a copy of the form to the Dean. 3.11 Note: It is envisaged that most, if not all, research undertaken by taught postgraduate and undergraduate students will fall into either the low risk or no risk categories. 3.12 High Risk. Research in this category includes (but is not restricted to) research involving vulnerable groups (including adults in an asymmetric power relationship with the researcher, such as the researcher’s students or employees, but also including e.g. children and young people, those with mental impairment, etc); research involving intrusive or covert methods; research that might expose the researcher to higher than usual risks. This list is indicative only and is not meant to identify all such categories. Such research will normally be required to be submitted through the EAC (see Section 4 below). 3.12.1 All students (postgraduate research or taught, and undergraduates) should send the ethical approval application form to their supervisor. The supervisor will confirm that the research is ‘high risk’ and forward a copy of the form to the designated person in the relevant qualification programme team who is responsible for co-ordinating the authorisation of the ethical approval application forms (eg programme manager). This individual will, in turn, send the form to the EAC. 3.12.2 Members of staff should forward a copy of the form to the Dean, who will send it to the EAC. 3.12.3 Visiting research staff should forward a copy of the form to their LIBF supervisor or mentor. This individual will confirm that the research is ‘high risk’ and forward a copy of the form to the EAC. 3.12.4 The EAC will review all ethical approval application forms where the research is proposed to be ‘high risk’ and may:
the risks identified, with no conditions;
the measures proposed for mitigating the risks identified, or other related aspects;
modifications to the research design, or similar;
into this category, it is conceivable that a project might be proposed that involved risks to the researcher or research participants incommensurate with the potential findings, or methods deemed detrimental to the LIBF’s good standing, with no appropriate means proposed for mitigating those risks. 3.12.5 A member of the Faculty will replace the Dean for research involving them. Next Steps 3.13 Notification of Ethics Approval Application Outcome
programme manager) or the EAC, as appropriate, will also retain on file copies of the complete and approved ethical applications (with approval reference and a record of any conditions imposed), information sheets, consent forms and a record of any arising issues notified and response provided. These records will be retained for three years following completion of the project in the case of now-risk or low-risk applications, and for five years following completion of the project in the case of high-risk applications. 3.14 Appeals 3.14.1 Researchers may refer decisions relating to ethical approval referrals and refusals back to the EAC, clearly stating the grounds for their appeal. 3.14.2 If the EAC confirms its decision, the researcher may appeal (in writing) to the Academic Board (or a specially-convened sub-committee thereof). The Academic Board’s decision will be final. 4 Complaints 4.1 If preliminary discussions as outlined in sections 4. 2 and 4. 3 below result in a decision to pursue an investigation, this will be carried out in accordance with the procedures outlined in section 5 for investigating allegations of research misconduct (since an allegation of unethical practice is an allegation of research misconduct, see section 5 .1 below). Student Research 4.2 Research participants who believe that they have in some way been harmed by a student’s research should in the first instance address their concerns to the student’s supervisor (whose name should be included on the information sheets provided to participants). They will consult with the EAC and decide whether to proceed to a formal investigation. (This stage represents the ‘informal enquiry’ stage; see section 5 .2 below.) Research by other members of the Academic Community 4.3 Research participants who believe that they have in some way been harmed by research undertaken by non-student members of LIBF’s academic community should in the first instance address their concerns to the EAC. They will decide whether to proceed to a formal investigation through LIBF’s disciplinary procedure. 5 Procedures for Managing Research Misconduct 5.1 Definition of Research Misconduct. 5.1.1 This section of the framework draws in particular upon the following two documents: 5.1.1.1 UKRIO Procedure for the Investigation of Misconduct in Research (2008)^6 ; 5.1.1.2 RCUK Policy and Guidelines on Governance of Good Research Conduct (20 15 ).^7 (^6) UKRIO. (2008). Procedure for the Investigation of Misconduct in Research. Available at: http://www.ukrio.org/wp-content/uploads/UKRIO-Procedure-for-the-Investigation-of-Misconduct-in- Research.pdf [Accessed: 11 May 2020 ].
5.1.2 The purpose of these guidelines is to ensure that research is undertaken according to the highest standards, and that research misconduct is avoided. Research misconduct includes (but is not limited to) the following examples (see UKRIO 2008, pp.27-9; RCUK 2013 , pp.6-10): 5.1.2.1 Failure to conduct research according to the established ethical procedures of the academic research community, for example: failure to exercise appropriate care in respect of responsibilities relating to avoidance of harm to human participants or the environment; failure to gain informed consent; undertaking research prior to or without gaining ethical approval; failure to exercise due care in the handling of privileged or personal data. 5.1.2.2 Failure to conduct research ethically and with integrity, for example: fabrication; falsification; misrepresentation of data and / or interests; withholding of data that affects the findings; and or involvement; or plagiarism in proposing, performing, or reviewing research or in reporting research results. 5.1.2.3 It is important to note that research misconduct can occur through acts of omission as well as acts of commission. 5.1.2.4 These examples are intended to be indicative of research misconduct and should not be regarded as definitive. 5.2 Overview of Procedures for Investigating Complaints and Allegations of Research Misconduct 5.2.1 As a general principle, any complaints or allegations of research misconduct against members of LIBF’s academic community should be investigated as expeditiously as possible. 5.2.2 For both students and other members of LIBF’s academic community, the initial stage will be one in which informal enquiries are made and a decision is reached either that there is no case, or that misconduct may have occurred. Informal Enquiries 5.2.3 Any complaints or allegations should be made in the first instance, in confidence, to the student’s supervisor, or, in the case of complaints against other members of LIBF’s academic community, to the EAC. 5.2.4 In the case of students, the student’s supervisor will consult with the EAC. Discreet enquiries may be undertaken at this point by an independent investigator. 5.2.5 Such enquiries may lead either to the complaint or allegation being dismissed, or to the decision to pursue the case through a formal investigation. From this point procedures for students and members of the academic community differ, as outlined below. (^7) RCUK. (201 3 ). RCUK Policy and Guidelines on Governance of Good Research Conduct. Available at: https://www.ukri.org/files/legacy/reviews/grc/rcuk-grp-policy-and-guidelines-updated-apr- 17 - 2 - pdf/ [Accessed: 11 May 2020 ].
5.2.15 The student should be provided with a written statement of the case against them and the evidence pertaining to that case. They should be invited, with sufficient notice, to attend the panel that hears their case; and should also be invited to bring with them a union representative, colleague or friend (but not a legal representative). 5.2.16 If the complaint or allegation is dismissed, the student and the complainant will be informed in writing. 5.2.17 If a complaint or allegation is upheld penalties may range from further developmental training (for inadvertent breaches) through to more serious penalties for severe breaches, up to and including expulsion from LIBF or removal of the award. Appeals Process 5.2.18 Students who have been found guilty of research misconduct have the right of appeal. Such an appeal should be lodged with the EAC within four weeks of the initial panel. 5.2.19 Appeals will be heard by a committee comprising members of the Academic Board. 6 Research Ethics Training General 6.1 All staff and students involved in or undertaking research should undertake appropriate training relating to research methods generally and academic research ethics in particular (ESRC 201 5 , RCUK 20 15 ). This research methods training should encompass inter alia the methodological underpinnings of research, research design, data collection, analysis, and maintenance, and the ethical implications of these aspects. Such training should also include coverage of the processes and procedures for obtaining ethical approval for research, for managing data, and so on. Students 6.2 Research training, including training in academic research ethics, should be commensurate with the training need and the potential risk and complexity of the research projects undertaken. Postgraduate Taught and Undergraduate Students 6.2.1 Students on taught courses involving a research-based dissertation or project should undertake a specific credit-bearing taught research methods course (either as a stand- alone module or explicitly incorporated into and taught as part of the dissertation / project module) that includes ethical training as a component. Staff Members of the Academic Community 6.3 Not all staff within LIBF will be interested in or engaged in undertaking significant research, but many staff may be involved in supervising students’ dissertations, at least at
undergraduate level. Thus as a minimum, and as a general principle for staff research training: Researchers 6.3.1 Staff involved in research with or for LIBF should normally have undertaken formal research skills training, for example as part of a postgraduate qualification, and be familiar with this FRE and processes. Supervisors 6.3.2 Staff responsible for supervising students’ dissertations and projects, whether at undergraduate or postgraduate level, should receive appropriate training for the role. 6.3.3 This training should include developing an awareness of their responsibilities vis-à-vis the ethical issues relating to the research undertaken by the students under their supervision, such that they can guide their students to develop ethically-sound research projects, help their students think through potential issues, be confident in signing off research ethics forms, and knowing when it is appropriate to refer them / refuse to sign them off, and so on. 6.3.4 No member of staff should supervise a postgraduate taught masters dissertation if they have not as a minimum themselves undertaken a masters qualification involving a dissertation. 6.3.5 New supervisors should be mentored by more experienced research staff. November 2015 Updated January 201 7 Updated May 2020 Updated November 2020