3The Concordat to Support Research Integrity
Background
29.The Concordat to Support Research Integrity was developed by Universities UK (UUK) in 2012. The objective of the Concordat approach was to “work within existing systems and structure, and to provide a clear stimulus for concerted action” by articulating “a set of common expectations and commitments in a comprehensive and coherent national policy framework”.52 The Government’s response to our predecessor’s report in 2011 stated that, through the Concordat, “the Government will expect employers of researchers to deal with research integrity in an open and transparent manner”.53
30.The Concordat sets out five high-level commitments to research integrity:
- We are committed to maintaining the highest standards of rigour and integrity in all aspects of research.
- We are committed to ensuring that research is conducted according to appropriate ethical, legal and professional frameworks, obligations and standards.
- We are committed to supporting a research environment that is underpinned by a culture of integrity and based on good governance, best practice and support for the development of researchers.
- We are committed to using transparent, robust and fair processes to deal with allegations of research misconduct should they arise.
- We are committed to working together to strengthen the integrity of research and to reviewing progress regularly and openly.
Within each of these there are various recommendations on how to meet those high-level commitments. The Concordat has eight formal signatories, including the research councils and funding councils, the Wellcome Trust, and UUK.
31.Almost all written submissions we received were positive about the Concordat as a concept. UUK advocated this approach over greater regulation, to avoid “presenting research integrity as an issue of compliance, rather than embedded through the lifecycle of research production and dissemination, and a cultural norm”.54 They also told us that the high-level nature of the Concordat ensured that the diversity of the sector was recognised, and that institutions could “implement its provisions in a manner appropriate to their specific context and strategic focus”.55
Progress in implementing the Concordat
32.UUK published a Progress Report on the implementation of the Concordat in 2016.56 They told us that “significant progress” had been made through the Concordat “in delivering greater coordination between the critical partners in supporting research integrity”.57 However, the Progress Report also suggested that there was still some way to go in ensuring that all UUK members fulfil its recommendations.
33.We wrote to all 136 UUK members in November 2017 to seek up-to-date figures on compliance. We asked them to confirm whether they fulfil three of the more specific recommendations of the Concordat:
- Identify “a senior member of staff to oversee research integrity and to act as first point of contact for anyone wanting more information on matters of research integrity”;
- Provide “a named point of contact or recognise an appropriate third party to act as confidential liaison for whistleblowers or any other person wishing to raise concerns about the integrity of research being conducted under their auspices”; and
- Publish a short annual statement on research integrity, incorporating:
- “a summary of actions and activities that have been undertaken to support and strengthen understanding and application of research integrity issues (for example postgraduate and researcher training, or process reviews)”
- “a high-level statement on any formal investigations of research misconduct that have been undertaken”.
The results of our survey are presented in Annex A, with the full individual responses available online.58 We were pleased to find that, in virtually all cases, universities could point to an individual with responsibility for research integrity and a whistleblowing contact. We did not attempt to assess whether this information was also easily available online for others to access, but we hope that our decision to publish the information we received will prompt UUK members to check that this is the case.
34.However, there was significant variation on the publication of an annual statement:
- 58% of Universities UK members published an annual narrative statement on research integrity, and were able to provide us with a link to either a 2015/16 statement or 2016/17 statement, or both.
- A further 17% indicated an intention to publish their first annual statement shortly. Indeed, several cited our survey as a prompt to do so, including Bangor University, University of Greenwich, and others.
- 25% did not currently publish an annual statement and did not indicate an intention to do so in the future.
Of those UUK members that did not publish an annual statement, the majority told us that this was because there had been no investigations to report since the Concordat was signed—although many other universities did publish explicit nil returns.
35.A handful of institutions cited concerns about confidentiality as being a barrier to them publishing an annual narrative report, or suggested that doing so would cause image problems for the university. For example:
- The University of South Wales told us that it does not publish information on instances of research misconduct, since “there are confidentiality issues embedded within such a disclosure that should be protected.”59
- The University of Bedfordshire claimed that it “adheres to the principles of the Concordat”, but that to publish information it would “need to consider the legitimate interests of a range of parties” and “bear in mind that in such cases the preservation of individual and contractual confidential [sic] would be among our considerations”.60
- Middlesex University told us that it does not routinely report investigations publicly because public disclosure is not appropriate in all cases, and “certainly not for cases where a formal investigation may have been instigated but where the individual concerned was completely exonerated”. The University claimed that it was “fully signed up to the Concordat”, but that it had “chosen not to separate research integrity, and research ethics in general, for special treatment”, since “to single out research integrity/ethics could, we believe, run the risk of it being perceived as being more important than other equally significant matters (e.g. misconduct in relation to our equality and diversity agenda).”61
- Birkbeck University told us that it was “more challenging to implement” the annual statement than other aspects of the Concordat. The University explained that “This is in part due to our small size—i.e. we rarely receive either formal or informal allegations of research misconduct, and so would be reporting on at most one (or, very occasionally, two) case(s) per year based on current levels. This obviously presents us with challenges both in terms of protecting the identities of those involved and with how to represent the information in a way that doesn’t over-inflate the scale of the problem.”62
36.The significance of universities failing to produce an annual report on research integrity was emphasised several times during our inquiry. Dr Elizabeth Wager told us that “secrecy surrounding investigations perpetuates the myth that major institutions are somehow immune from misconduct”, and that “annual accounts of the number of investigations and their outcomes will increase transparency and therefore trust in our institutions”.63 Research Councils UK (now defunct following the formal creation of UK Research and Innovation in April 2018) told us that there was “strong awareness” of the Concordat among “senior leaders, research managers and administrators responsible for implementation at institutions”.64 Nevertheless, the Vice-Chancellor at Regent’s University London replied that “ I must admit that I had not heard of the Concordat and it had not been brought to my attention. This may be because Regent’s did not gain University title until 2013 and was not admitted to Universities UK membership until 2014”.65
37.We asked Sir Ian Diamond, representing UUK, whether progress with implementing the Concordat had been rapid enough under UUK’s leadership. He told us:
I am very clear that there is a really rapid change in awareness and importance. Is it fast enough and are we there yet? No.66
However, he also told us that Universities UK itself does not have a role in requiring universities to comply,67 and that “universities are autonomous institutions”.68 When we put it to him that leadership was required to drive implementation, he told us that UUK was showing leadership and was “asking people to do things”.69 UUK subsequently wrote to us to set out the steps it was now taking in response to the issues raised by the inquiry, including plans to convene a Research Integrity Forum meeting in 2018 where issues relating to the Concordat can be discussed with the eight signatories.70
38.We asked Sir Mark Walport whether seeking 100% compliance with the Concordat was a reasonable aim. He argued that institutions that carry out the majority of publicly-funded research were already complying, and that those that publish annual statements account for over 80% of public funding for research:71
It is important to recognise that some institutions have a very small amount of research activity. The really important issue is to make sure that those institutions that are doing significant amounts of research are reporting. All the evidence is that they are. […] There is room for improvement; I do not think anyone argues with that.72
We were encouraged by the Science Minister’s more robust response on the question of current compliance levels:
I do not think [compliance] is good enough, and UKRI should be using its lever of funding to get more institutions to comply. We should be aiming for 100% where it is public funding, and I take that extremely seriously. My personal expectation of every vice-chancellor is that there should be 100% compliance […] it is not enough for any university in receipt of public funding just to have a web page.73
39.Most universities take their research integrity responsibilities seriously, but progress in implementing the Concordat to Support Research Integrity across the whole sector is disappointing. Six years on from the signing of the Concordat, the sector as a whole still falls some way short of full compliance in terms of publishing an annual statement, which risks giving the impression of pockets of complacency. We were surprised by the reasons that some universities gave for not publishing an annual statement on research integrity as recommended by the Concordat. The majority of universities have successfully balanced transparency against confidentiality in producing an annual statement, but a few are lagging behind and see transparency as a threat to their public image. Publishing an annual statement is a positive opportunity for an institution to set out the steps that it is taking to safeguard research standards, as well as to report on the number of investigations. We were encouraged that our letter to all Universities UK members prompted some of them to take steps to improve their compliance with the Concordat. More leadership is required to drive the implementation of the Concordat across the whole of the research sector, and we return to this issue in Chapter 6. We welcome Universities UK’s plans to convene a Research Integrity Forum meeting to consider our recommendations relating to the Concordat and look forward to seeing the results of their work.
Monitoring and incentivising compliance
40.In 2013, compliance with the Concordat became a prerequisite for receiving research funds from the higher education funding councils74 and UK research councils. Witnesses cited this as an important contributor to the success of the Concordat.75
41.Research councils and funding councils have operated separate processes for monitoring Concordat compliance. The Higher Education Funding Council for England (HEFCE, now superseded by Research England) described how compliance had improved among the institutions in England that it funds, from 25% of institutions reporting in 2013/14 that they were still ‘working towards’ compliance with the Concordat, decreasing to 1.6% by 2015/16. This claimed low level of non-compliance does not tally with our work on assessing annual reporting rates, and perhaps reflects the somewhat vague nature of tracking “compliance with Concordat” when it contains only recommendations rather than explicit measurable requirements. RCUK did not appear to be able to provide equivalent information for the wider group of UK institutions it funds. Dr Tony Peatfield of RCUK explained that the research councils’ monitoring process was through ‘dipsticking’ a selection of institutions each year, and so could not provide comprehensive compliance figures.76
42.According to UUK, the research and funding council requirements mean that “institutions can face sanctions should they be shown to be failing to meet the commitments, providing a robust mechanism to ensure its adoption and implementation”. However, evidence from the Higher Education Funding Council for England (HEFCE, now replaced by Research England) and Research Councils UK revealed that such sanctions have never been deployed, despite the shortcomings in compliance we identified. HEFCE told us that:
In last year’s funding return we had two institutions [in England] that were not compliant […] we favour carrots, rather than sticks. That triggered a process with those institutions that involved very close contact with them, the requirement to develop an action plan and following up that action plan. I am pleased to say that in this year’s return both those institutions are now compliant. This year we have two different institutions that are not compliant.77
Dr Peatfield told us that, where cases of non-compliance are identified, the research councils also “much prefer carrots to sticks” and “tend to try to work with the institutions”.78 The research councils have also not prevented any organisations from applying for funding. Dr Peatfield explained that imposing sanctions after funding has been provided is ineffective for project-based funding since “often by the time that a case [of misconduct] is proven the research grant will have ended, so withdrawing that funding is not feasible”.79 Dr Steven Hill, representing HEFCE, noted that the creation of UK Research and Innovation in April this year—bringing together the seven research councils with Research England and Innovate UK—created some opportunities for better alignment of research council and funding council assurance processes in the future.80
43.Compliance with the Concordat has technically been a condition of receiving funding from research councils and higher education funding councils since 2013, but meaningful sanctions have never been deployed. The Concordat contains mainly high-level statements rather than explicit measurable requirements, and comprehensive information on ‘compliance’ is not collected by the funders. We recommend that the signatories update and strengthen the Concordat by making the requirements and expectations clearer, and produce a route map and timetable for reaching 100% compliance with the strengthened version within the next year. UKRI should collect and publish details of universities that are not compliant. In particular, the Concordat should be strengthened in relation to training on research integrity (discussed in Chapter 4), processes for responding to allegations of misconduct (see Chapter 5), commitments to clinical trials transparency (which we will return to in a dedicated report) and publication of ‘negative’ research results.
Research integrity in Government departments
44.The Science Minister told us that “the standards for research funded and undertaken by Government departments is the responsibility of departmental Chief Scientific Advisors, with oversight provided by the Government Chief Scientific Advisor [GCSA]”.81 We wrote to each of the Government’s departmental Chief Scientific Advisors (CSAs) in December 2017 to ask about responsibility for research integrity within their department and the processes followed when issues are identified in relation to research work undertaken or commissioned by the departments.82 We were pleased to hear that Dr Patrick Vallance, the new GCSA, expected all departments to have a CSA,83 and that the Department for Digital, Culture, Media and Sport was appointing a CSA.84
45.Dr Vallance’s view was that “Departments should sign up to the Concordat, that the chief scientific advisers in the Departments should lead that process and that we should aim for a somewhat more consistent approach to how we think about research integrity”.85 We were pleased to learn that he had written to all CSAs on this point, prompted by our inquiry.86
46.We endorse the Government Chief Scientific Adviser’s call for Government departments to sign up to the Concordat on Research Integrity to ensure consistency of approaches to research governance. If the Concordat is suitably strengthened, as we recommend above, this will be a useful step forward. We look forward to receiving further details of actions taken by the departments in response to his initiative in the Government’s response to this report.
53 Science and Technology Committee, Tenth Special Report of Session 2010–12, Peer review in scientific publications: Government and Research Councils UK responses to the Committee’s Eighth Report of Session 2010–12, HC 1535
56 Universities UK, The Concordat to Support Research Integrity: A Progress Report (November 2016)
74 HEFCE, ‘Compliance with the Concordat to support research integrity’, Circular Letter 21/2013
81 Letter from Sam Gyimah MP to Rt Hon Norman Lamb MP, February 2018
Published: 11 July 2018