Further supplementary written evidence
submitted by the UK Research Integrity Office (PR 84b)
Letter from Professor Sir Ian Kennedy,
Chair, UK Research Integrity Office,
to the Chair of the Committee, 20 June 2011
1. I write further to the oral evidence to the
above inquiry of Professor Rick Rylance of Research Councils UK
(RCUK), David Sweeney of the Higher Education Funding Council
for England (HEFCE) and Sir Mark Walport of the Wellcome Trust.
Regrettably, some of the comments made regarding the UK Research
Integrity Office (UKRIO Ltd.), which I chair, were inaccurate.
2. I was surprised at the criticism that UKRIO
Ltd. in its first phase did not provide support to all disciplines
of research. UKRIO was in fact conceived to support the UK life
sciences research community as a pilot for a wider remit. Since
our inception, we have responded to enquiries on issues of research
integrity across all subject areas and our published guidance
is applicable to all disciplines.
3. The research community has been aware of this
for some time. In 2009, RCUK's Policy and Code of Conduct on
the Governance of Good Research Conduct recommended UKRIO's
Procedure for the Investigation of Misconduct in Research,
while the Economics and Social Research Council's Framework
for Research Ethics (2010) included material from our Code
of Practice for Research and cites UKRIO as a source of advice
on issues of research integrity. These publications are binding
on those in receipt of funds from the relevant organisation. Neither
suggests that UKRIO or its guidance is applicable only to health
and biomedicine. Indeed, demand from employers and researchers
led us to support all disciplines of research from early in our
first phase, including cross-disciplinary research, and we continue
to do so.
4. During discussion of UKRIO Ltd., it was suggested
that research integrity is an intrinsic responsibility of employers
of researchers and should not be delegated. UKRIO Ltd. agrees
entirely with the view that employers have the primary responsibility
for the conduct of their researchers and for research carried
out under their auspices. However, to suggest that employers delegate
such responsibilities to UKRIO Ltd. shows a misunderstanding of
our work and the reasons for our creation.
5. UKRIO was established by a consortium of funders
to support employers of researchers. That is, to support the institutions
which are legally responsible for resolving most issues of research
conduct. We have never proposed that employers should delegate
their responsibilities to us; instead we provide independent and
expert advice on how they might fulfil them. The advice and guidance
we offer is not mandatory. It reflects best practice in the conduct
of research and addressing misconduct. This method of support
has been welcomed: our published guidance has been adopted or
otherwise used by many research organisations, including by over
fifty universities, while in 2010 alone we helped with more than
60 cases (over one a week). It is evident that employers, well
aware of their legal responsibilities for research integrity,
are willing to come forward and seek guidance from UKRIO Ltd.
when they need it.
6. It is not surprising that research funders
say that UKRIO has not delivered an assurance mechanism on their
behalf. It was never created to perform such a function, which
has remained the responsibility of funding bodies. Rather, UKRIO
was created to fill a gap in support to employers, to researchers
and to the public. This has been achieved. I would argue that
UKRIO Ltd. does indirectly support the work of research funders
by promoting and improving research integrity in the organisations
in receipt of their funds. It is regrettable that this was not
acknowledged.
7. Organisations which provide funds for research
must of course satisfy themselves that those funds are used appropriately.
They have the power to operate appropriate assurance mechanisms
through the terms and conditions of their grants and awards. UKRIO
Ltd. welcomes efforts to streamline and harmonise such mechanisms,
to ensure clear and proportionate guidance for the research community
and avoid duplication of effort. We remain willing to contribute
to the development of initiatives such as the proposed Concordat,
which could benefit from our considerable expertise and unique
practical experience. We agree that assurance and advisory functions
must remain separate but that does not weaken the case for drawing
on a common repository of skills and information.
8. Regardless of the assurance mechanisms used
by research funders, employers, researchers and the public still
need wider support on issues of research integrity, support which
UKRIO Ltd. will continue to provide. Both the sponsors who created
UKRIO and the UK Research Integrity Futures Working Group concluded
that only an independent advisory body could win trust and successfully
offer confidential and expert support to institutions, researchers
and the public. In today's economic climate, it is unlikely that
any other organisation will take forward the recommendations of
the Working Group and provide an advisory service on issues of
research conduct. While we recognise that none of the organisations
concerned would have made such a decision lightly or willingly,
this will leave the UK research community and the public in danger
of having insufficient support on matters of research integrity
and risks damaging our national reputation.
9. UKRIO Ltd. is therefore convinced that it
must continue. The cost is modest compared with the much more
ambitious plans that some stakeholders had envisaged as necessary
for a research integrity body and are minimal compared to the
damage from research misconduct and poor practice. UKRIO Ltd.
operates very cheaply and cost-effectively, with a very small
staff backed by a Board and a register of expert advisers, both
of which work pro bono.
10. We welcome the initiatives being undertaken
by research funders to support research integrity. Theirs is a
valuable perspective, alongside those of Government, statutory
regulators, employers in the higher education, NHS and private
sectors, research charities, learned societies, professional organisations,
specialist bodies such as UKRIO Ltd. and, not least, researchers,
research participants and the public. All have an important contribution
to make in support of research integrity. In particular, I feel
it would be unfortunate if the unique experience, expertise and
data massed by UKRIO since its creation were not drawn upon by
others to inform initiatives in this field.
11. How research integrity might best be supported
in the UK has been the subject of considerable discussion over
many years. As you know, UKRIO was established as a result of
such discussions. It is clear that researchers and those personnel
who deal with issues of good practice and misconduct on behalf
of their organisation value being able to seek our advice. They
have welcomed the establishment of UKRIO, as shown by the continuing
rise in the use of our services. We would not be approached for
assistance if we were not needed. Discussions will undoubtedly
continue on how other bodies might support research integrity
and we remain ready to inform and participate in this process.
Meanwhile, UKRIO Ltd. will continue to raise the profile of good
practice in research and address misconduct. Our significant achievements
to date in identifying and responding to concerns about research
integrity provide the foundation for UKRIO Ltd. to continue to
provide a much-needed service.
Professor Sir Ian Kennedy,
Chair, UK Research Integrity Office
June 2011
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