Responsible Conduct of Research – Procedure

1. Purpose 

This procedure establishes the college’s guidelines and process to address allegations of violations of research integrity at Loyalist College in alignment with the Tri-Agency Framework: Responsible Conduct of Research. Any allegation of a breach of research integrity must adhere to the following process for identification, investigation, and resolution.

2. Application 

This procedure applies to all employees, students, and any other individuals engaged in research in any capacity through the college, including authorized external researchers whose research is facilitated by the college.

Students who are alleged to have engaged in in a breach of research integrity solely within their capacity as students, and in respect only to work related to the completion of course or program requirements, will be governed by ACAD 206 Academic Integrity policy.

In the event of a discrepancy between the Tri-Agency policies and this procedure, the Tri-Agency policies will prevail.

3. Roles and Responsibilities   

Researchers will:

• Follow best research practices honestly, accountably, openly, and fairly in the search for, and in the dissemination of, knowledge in adherence to all college, Agency, and partnership requirements and policies.
• Report instances of a breach.
• Cooperate and participate in any required processes under this procedure in good faith, while respecting the privacy of others involved and the confidentiality requirements of the process.

The Executive Director, Indigenous Engagement and Applied Research (or designate) will:

• Receive and respond to reports of a breach under this policy, including any confidential initial conversations with the complainant, respondent, or other relevant individuals to establish the validity of the allegation.In instances warranting an investigation, appoint an investigation committee and direct any immediate/interim measures required to protect the integrity of the investigation process.
• Receive the investigation committee’s report and consult with the appropriate Loyalist College representatives or external bodies in achieving a decision in investigation scenarios.
• Communicate with the complainant and respondent throughout the process, including the college’s final decision within investigation scenarios.
• Communicate and collaborate with any agencies and the Secretariat on the Responsible Conduct of Research (SRCR), as required and as appropriate.

The Investigation Committee will:

• Complete a confidential investigation into the facts of the alleged breach, notifying the Executive Director, Indigenous Engagement and Applied Research of the outcome.
• Summarize the findings of the investigation into a report within the designated timeframe.
• Declare any actual, perceived, or potential conflict of interest.

The President and CEO will:

• Receive and respond to reports of a breach in instances where the respondent is the Executive Director, Indigenous Engagement and Applied Research.
• Oversee and preside over the appeals process, should an appeal be made under this procedure.

The Manager, Research Administration will:

• Provide appropriate support mechanisms that guide and ensure research is conducted with honesty, integrity, and intellectual competence, including the management and review process of this policy and procedure.
• Promote and communicate practices regarding the importance of responsible conduct in research and that articulate the high level of ethical standards required to create and maintain a supportive research environment.
• Communicate and collaborate with agencies, funding bodies, and the Secretariat on the Responsible Conduct of Research, as required.
• Collaborate with the Executive Director, Indigenous Engagement and Applied Research to determine appropriate immediate measures, interim measures, and resolution measures under this policy.

4. Responding to an Allegation of a Breach of Research Integrity  

The college holds the responsibility of addressing research integrity breach allegations, ensuring all reporting requirements and time limitations are met, and providing support to all community members who engage in these processes. All concerns and complaints related to research integrity will be addressed in a manner that is timely, fair, and confidential.

4.1 Obligation to Report

All individuals involved with research have an obligation to confidentially report, in good faith, any circumstances that constitute a possible breach of research integrity and/or RES 102 Responsible Conduct of Research.

4.2 Anonymous Complaints

Loyalist College will consider and review all anonymous complaints submitted. While the anonymity of the complainant may limit the ability to fully investigate or resolve the matter, the college is committed to assessing all submissions seriously.

Where appropriate, the college may initiate an investigation based on the information provided, even in the absence of an identified complainant. These investigations may differ from the standard procedures outlined, as they are adapted to the available information.

All anonymous complaints are reviewed and included as part of the college’s annual reporting to the Secretariat on Responsible Conduct of Research and continuous improvement processes as they assist in informing policy and operational enhancements that support a responsible research environment.

4.3 Confidentiality

The college has a responsibility and obligation to ensure that any private and personal information provided in the disclosure, report, and/or investigation of a breach is collected, used, maintained, and secured appropriately. Access to such information will be restricted to those individuals with a legitimate need for access.

The college will make every effort to maintain the confidentiality of all persons involved in disclosing or reporting, including witnesses. All persons involved in the disclosure, reporting, assessment, and/or investigation of an allegation are required to keep this information confidential.

Information concerning a policy breach will be communicated to any applicable stakeholders of the research project, which may include but is not limited to, sponsoring agencies or industry partners, partnering academic institutions, local, provincial, or federal grant agencies, peer-reviewed journals, or other publications (if the research has been published), to ensure the college’s compliance with outlined requirements.

4.4 Support Persons

A support person may accompany a complainant, respondent, or witness to their inquiry or investigation meetings. Their purpose is to provide emotional support. They may take notes on behalf of the person they accompany. A support person is not permitted to question or make comments during the proceedings. Possible types of support persons include but are not limited to individuals that assist people with disabilities, Elders or Knowledge Keepers (including individuals from the Tsi Titewaya’tarό:roks Indigenous Centre), friends, and relatives. Support persons are commonly not legal advisors or lawyers and should not be anyone who has a conflict of interest with the situation.

4.5 Union Representation

Unionized employees have the right to union representation at all stages of the procedure. If both the respondent and complainant are represented by the same union, the union will take appropriate measures to ensure both members receive separate and confidential union representation.

4.6 Interim Measures and Immediate Actions

In exceptional circumstances, depending on the severity and urgency of the alleged breach of research integrity, the possible consequences, and the potential financial, health, safety, or other risks involved, the college reserves the right to take interim measures or immediate actions upon receiving the allegation, or may be directed by the Tri-Agencies or SRCR to do so. Such actions could include freezing grant accounts, requiring a second authorized signature from an institutional representative on all expenses charged to the researcher’s grant accounts, or other measures, as appropriate. The rights and privileges of a respondent may be restricted by the college before it makes a final determination about the alleged breach to uphold the integrity of the process.

The Executive Director, Indigenous Engagement and Applied Research or their designate will inform the appropriate individuals at the college on a confidential basis to implement any interim measures or immediate actions. Subject to any applicable laws, including privacy laws, the college must advise the relevant agency or SRCR immediately of any allegations related to activities funded by an agency that may involve significant financial, health and safety, or other risks.

Interim measures and/or immediate actions are imposed to protect the interests of all parties and imposed only as necessary. Respondents may ask the Executive Director, Indigenous Engagement and Applied Research to review a decision to impose interim or immediate measures, but only to address the impact of the imposed measure and the preference of other alternatives.

4.7 Time Limitations

Individuals are encouraged to report instances of a breach at their earliest opportunity to ensure the quality of the inquiry and investigation phases.

In compliance with reporting requirements set out by the Secretariat on the Responsible Conduct of Research (SRCR), the college will review and complete the inquiry phase of the process within two months of the receipt of an allegation. Should an investigation be warranted, the college will complete the investigation and make its investigation report to the SRCR within five months following the end of the inquiry phase.

These timelines may be extended in consultation with the SRCR if circumstances warrant an extension. The college will endeavour to complete the processes in a timely manner while ensuring due process.

4.8 Allegations Involving Other Institutions

Should an allegation be made that involves actions that occurred at another institution, the college will contact the other institution to jointly determine whether the inquiry and investigation processes will occur at Loyalist or under the direction of the other institution. In such instances, the college will communicate the decision made to the complainant and provide the point of contact for the allegation process.

5. Procedure for Investigating Allegations of a Breach of Research Integrity

Step One. Intake of Allegation

Allegations, including anonymous allegations, must be made in writing and submitted in a confidential manner to the Executive Director, Indigenous Engagement and Applied Research or their designate. In instances where an employee is reporting a complaint and the respondent is the Executive Director, Indigenous Engagement and Applied Research, the complaint may be made to the President and CEO or their designate.

Upon receipt of the allegation, the Executive Director, Indigenous Engagement and Applied Research or their designate will meet with the complainant to gather more information, if required. This meeting will aim to collect all necessary details to complete the allegation and the Executive Director, Indigenous Engagement and Applied Research or their designate will:

• record the concerns and allegations using Appendix A Research Policy Breach Reporting Form. 

• ensure the complainant fully understands the necessity and limitations of confidentiality within the process.  

• advise the complainant of their right to procedural fairness, including the right to file a written complaint and the right to be accompanied by a support person. 

Step Two. Initial Inquiry  

The initial inquiry into a breach allegation will be conducted by the Executive Director, Indigenous Engagement and Applied Research or their designate to establish whether an allegation is responsible and an investigation required. Alternatively, the inquiry may be conducted by one or more individuals and include other individuals qualified to assess whether the allegation is responsible. The individual(s) conducting the inquiry will be without conflict of interest, whether real, potential, or perceived. 

Within 10 business days of receiving the completed allegation, the Executive Director, Indigenous Engagement and Applied Research or their designate will inform the respondent of the allegations in writing and provide the process for the initial inquiry.  

The Executive Director, Indigenous Engagement and Applied Research or their designate may elect to meet with the relevant parties to gather information or mediate disputes or misunderstandings and may consult confidentially within the college and externally if appropriate, to assist in determining if an investigation is warranted. The Executive Director, Indigenous Engagement and Applied Research or their designate will decide whether the allegation should proceed to a formal investigation and provide a decision in writing to the respondent and complainant. 

If the Executive Director, Indigenous Engagement and Applied Research or their designate determines that the allegation should not proceed to a formal investigation, or that insufficient evidence exists, the allegation will be dismissed. The respondent and complainant will be notified of this decision in writing, and all reasonable efforts will be made to protect or restore the reputation of the individual subjected to an unfounded allegation on a case by case basis.  

The college will write a letter to inform the SRCR of the conclusion of the inquiry phase and indicate whether the allegation is responsible or not. If elements of a breach are confirmed at the inquiry stage, an investigation report will be provided to the SRCR, following all reporting requirements outlined in Step Six. 

Step Three. Investigation 

If an investigation is warranted, the respondent and complainant will be promptly informed in writing.  

The Investigation Committee 

An investigation committee will be appointed by the Executive Director, Indigenous Engagement and Applied Research or their designate with the authority to decide whether a breach occurred. The investigation committee will include three members who have the necessary expertise and are without conflict of interest with at least one external member who has no current affiliation with the college.  

Investigations that pertain to projects falling under RES 103 Conducting Research by and with Indigenous Peoples and Communities or those conducted by an Indigenous researcher must include at least one Indigenous individual who has the necessary expertise and is without conflict of interest.  

While the investigation committee reports its findings to the Executive Director, Indigenous Engagement and Applied Research or their designate, the Executive Director does not participate in the investigation. 

The Investigation Timeframe 

The investigation will be timely, fair, and aim to address all relevant issues. The length of time an investigation requires will depend on the nature and complexity of the circumstances. The college recognizes that these processes may be stressful for the individuals involved, and as such, investigations will be conducted as quickly as possible while ensuring sufficient time for a complete, thorough, and fair investigation.  

An investigation must be, at maximum, completed within five months unless there are extenuating circumstances warranting a longer investigation that has been approved by the SRCR. Exceptions to this time limit will be communicated with all parties. 

The Investigation Process 

The investigation committee will be formed to review the information provided through the inquiry stage and conduct an investigation appropriate for the circumstances. The college will work with the SRCR to ensure compliance with any steps that must be taken throughout the investigation process. 

The respondent will be provided an opportunity to be heard as part of the investigation. The committee may interview relevant witnesses, and review any relevant data and evidence as required. The college will inform the complainant, respondent, and any witnesses that they have the option of being accompanied during all investigation interviews by union representation (if the employee is unionized) or another support person. Throughout the investigation, the complainant and respondent will be kept informed about the status of the investigation. 

To conclude the investigation process, a report of the findings and the final determination will be made in recognition of the timelines established by the SRCR. The investigation committee’s report will be provided to the Executive Director, Indigenous Engagement and Applied Research or their designate within 10 business days of the conclusion of the investigation process. 

Step Four. Decision and Notification 

The complainant and respondent will be provided with an investigation closure letter from the Executive Director, Indigenous Engagement and Applied Research or their designate within 10 business days of the conclusion of the investigation. The decision will be based on the severity of the breach, consultation with the SRCR and the appropriate Loyalist College representatives, and the findings of the investigation. 

The closure letter will include a written summary of the investigation committee’s findings and the action, if any, relating directly to that party that the college will be taking to bring closure to the allegations of a breach. The complainant has the right to know that corrective action has been taken, but not the specifics of any disciplinary action. 

Step Five. Resolution 

The college will determine the actions taken to resolve a breach of policy by considering the severity of the breach of conduct. Documented and substantiated complaints may result in the discipline of an employee, up to and including termination and/or discipline of a student, including termination of the research or discipline under STU 100 Student Code of Conduct.  

In instances where an allegation has been determined to be unfounded, all reasonable efforts will be made by the college to protect or restore the reputation of those subjected to an unfounded allegation. 

The college will endeavour to improve any processes, including training, that may be identified through the investigation process as requiring remedy to avoid future incidents of a breach. 

Step Six. Final Reporting 

The college will prepare a report for the SRCR on each investigation it conducts in response to an allegation of a breach related to a funding application submitted to an agency or to an activity funded by an agency.  

Subject to any applicable laws, including privacy laws, each report will include the following information: 

• the specific allegation(s), a summary of the finding(s), and reasons for the finding(s). 

• the process and timelines followed for the inquiry and/or investigation. 

• the respondent’s response to the allegation, investigation and findings, and any measures the respondent has taken to rectify the breach. 

• the investigation committee’s decisions and recommendations and actions taken by the college as a result. 

The report will not include information that is not related specifically to agency funding and policies or personal information about the researcher, or any other person, that is not material to the college’s findings and its report to the SRCR. 

Where the allegation of policy breaches is related to funding applications submitted to an external funding agency or to an activity funded by an external funding agency, Loyalist College and the researcher will not enter into confidentiality agreements or other agreements related to an investigation that prevent Loyalist College from reporting to the external funding agency through the SRCR. 

6. Appeals

A complainant or respondent may appeal the outcome of an investigation to the President and CEO or their designate. Appeals will only be considered on one of the following grounds: 

• a significant error occurred where the procedures outlined were not followed correctly. Such errors must be substantive in nature and ones which could have affected the outcome of the process. Mere clerical errors will not normally constitute a significant error. 

• there is significant new evidence that was not available at the time of the decision, and which has the potential to change the original decision. The failure to present evidence that was available at the time of the original review does not constitute new evidence. 

Any disciplinary action taken because of a breach may be subject to grievance under the relevant collective agreement or appealed to the President and CEO or their designate. An appeal to the President and CEO is not allowed when an employee elects to proceed under the grievance procedure. 

Appeals to the President and CEO or their designate should occur within 10 business days of the decision being communicated to the complainant and/or the respondent and be in writing. If either party appeals, a copy of the submission will be given to the opposing party to allow an opportunity to respond in writing within five business days. 

The President and CEO or their designate will review the investigation report, the decision, the appeal submission, and response. If the President and CEO or their designate decides to hold a hearing, they will advise the parties of a date for an appeal hearing to take place. That hearing will be presided over by the President and CEO or their designate. The procedure at this hearing is meant to be informal and the President and CEO or their designate will determine the procedure to be followed at the hearing. Otherwise, the President and CEO or their designate will make a final decision based on the investigation committee’s report, the appeal submission, and the response. 

The President and CEO or their designate will provide a written decision with rationale to the parties as soon as reasonably possible. The parties will also be informed of any remedial action that will be taken, if appropriate. This decision is final and cannot be appealed.

7. Related Documents

• RES 102 Responsible Conduct of Research Policy
• RES 102 Appendix A Research Policy Breach Reporting Form
• ACAD 206 Academic Integrity
• ADMIN 107 Conflict of Interest
• ADMIN 128 Access to Information and Protection of Privacy
• Loyalist College Position on the Acceptable Use of Generative Artificial Intelligence
• RES 101 Financial Administration of Research Funds
• RES 103 Conducting Research by and with Indigenous Peoples and Communities
• RES 104 Ethical Conduct of Research Involving Humans
• STU 100 Student Code of Conduct

8. References  

• Canadian Council on Animal Care Guidelines, 2026
• Copyright Act, 1985
• Health Canada Laboratory Biosafety Guidelines, 2004
• Tri-Agency Framework: Responsible Conduct of Research, 2021