1. Purpose

This policy sets out Cancer Research UK's (CRUK) position on how researcher communities and Host Institutions that receive CRUK funding are expected to maintain good research conduct and support research integrity.

CRUK is committed to its mission of bringing forward the day when all cancers are cured. CRUK expects the research it supports to be conducted according to the highest standards of research practice to ensure the integrity and reliability of the research and outputs. 

CRUK is a Signatory to the Universities UK’s Concordat to Support Research Integrity (the Concordat) and is committed to maintaining high standards of research practice within the research communities we support. 

2. Scope

This policy applies to all CRUK-funded Host Institutions and individuals involved in research communities, including researchers, research support staff, research managers, administrators, and students.

In particular, we expect the CRUK Institutes (as defined in Section 3) to be at the forefront of implementing the steps, standards and practices outlined in Section 4. 

Host Institutions outside the UK are also expected to follow appropriate guidelines of a similar standard.

These Guidelines should be read in conjunction with the Research Integrity section of Cancer Research UK’s Grant Conditions. This policy complements CRUK’s policies and programmes of work on promoting positive research culture including open science, tackling bullying and harassment, equality, diversity and inclusion, researcher assessment and career development.

3. Definitions

Research integrity: CRUK, as a signatory to the Concordat, uses the definition and description of research integrity as outlined within that document with core elements of honesty, rigour, transparency and open communication, care and respect, and accountability. 

Research misconduct: we use the Concordat’s definition of research misconduct, and we expect Host Institutions we fund to do the same. The Concordat defines misconduct as “behaviours or actions that fall short of the standards of ethics, research and scholarship required to ensure that the integrity of research is upheld.” This includes fabrication, falsification, plagiarism or deception in performing or reviewing research, and in reporting research outputs. For example, failure to meet: legal, ethical and professional obligations, omitting relevant data, manipulating images, or misusing data by deliberately attempting to re-identify people from research data are all examples of research misconduct. 

Research can fall short in terms of its integrity for a number of reasons, many of which do not reflect the intent of researchers. Research misconduct does not include honest differences in the design, execution or interpretation in evaluating research methods or results, or research of poor quality such as poor research design, weak procedures or analysis, inadequate documentation or record-keeping unless this encompasses the intention to deceive.

Host Institution: the university, institution or other organisation at which some or all of the research funded by a CRUK grant will be carried out. 

Institute: the core-funded Cancer Research UK Institutes, namely the Cancer Research UK Beatson Institute, the Cancer Research UK Cambridge Institute, the Cancer Research UK Manchester Institute and the Francis Crick Institute.

4. Key Points

In this section:

4.1 Responsibilities for good research conduct

4.2 Responsibilities of the Host Institution to investigate unacceptable research conduct

4.3 Responsibilities of the Host Institution to report allegations to CRUK 

4.4 Why CRUK asks to be informed and what we do with this information

4.5 Sanctions

4.6 CRUK's right to investigate

4.1 Responsibilities for good research conduct

All those involved in CRUK-funded research have a responsibility to support the highest levels of research integrity. All staff, students and any associated personnel involved in a CRUK-funded research activity have a role to play in setting and maintaining standards and a positive culture, and reporting concerns or incidents if they do occur.

Principles of the Concordat to Support Research Integrity

As a Signatory to the Concordat, we expect staff, students, any associated personnel and Host Institutions involved in CRUK-funded research activity to abide by the principles set out the Concordat  (as amended) and to work with due respect for one another within a supportive environment.

The Concordat sets out five principles: 

1. Upholding the highest standards of rigour and integrity in all aspects of research; both the research itself and any resulting publications. 
2. Ensuring that research is conducted according to appropriate ethical, legal and professional frameworks, obligations and standards.
3. 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. 
4. Using transparent, timely, robust and fair processes to deal with allegations of research misconduct should they arise. 
5. Working together to strengthen the integrity of research and to review progress regularly and openly. 

Integration of research integrity principles into research culture 

It is the responsibility of Host Institutions and all those undertaking, supporting or otherwise engaged in CRUK-funded research to maintain a culture that nurtures good practice and where honest and ethical conduct of science is an expected norm.  That is, individual actions must comply with the principles of honesty, rigour, transparency and open communication, care and respect, and accountability for a research environment in which individuals and organisations are empowered and enabled to own the research process.

A supportive and honest research culture should be a central tenet of the leadership’s vision of success and permeate the behaviours and practices of individuals at every level.

We expect CRUK grantholders to take a leadership role in developing and role-modelling a positive and learning culture within their research teams where learning and development are prioritised, where colleagues can freely discuss good research practice and ask questions, raise concerns or admit errors; and where poor or questionable research practices are addressed and corrected. We expect this leadership role to include having difficult conversations with staff at all levels of seniority, and supporting others in their teams to do likewise, where this is necessary to improve the culture within which the research is taking place.

Staff and student induction sessions are a good opportunity for institutions to instil the tenets of the Concordat. All new research staff, students and visiting researchers should be encouraged to attend induction sessions on research integrity and an introduction to the policies and procedures. This should include how to respond to, and report, concerns about poor research practice or research misconduct. 

Effective people management is key to fostering a culture of research integrity and group leaders have a responsibility to mentor, supervise and support members of their group. All group leaders should be given the opportunity to improve/refresh their management skills through formal and informal training (e.g. EMBO’s Laboratory Management Course). 

Mentoring of new group leaders by senior staff is to be encouraged; particular guidance should be provided when a junior group leader recruits lab members for the first time. 

Institutions and researchers may also hold informal workshops/retreats for group leaders to share experiences and promote further development. 

Institutions must provide training to equip researchers with the skills, knowledge and resources to conduct science that is high-quality, ethical and valuable. Formal workshops or training courses may provide further guidance on practical measures to promote research integrity, such as responsible authorship and publication, avoiding plagiarism, experimental design, reproducibility, data management, appropriate use of statistical tests, record keeping, and responsible image processing. 

Researchers have a responsibility to raise concerns and report actual or attempted breaches of ethical, legal and professional frameworks, obligations and standards to the Host Institution. This should be done in line with published institutional guidance.

Peer review 

Peer review is a primary control route for maintaining good research practice. Regular meetings should be held to allow peers and group leaders to scrutinise each other’s research, including:  

• Students’ meetings 
• Individual lab meetings 
• Group Leader meetings 
• Departmental/Institute-wide meetings 
• Inter-disciplinary meetings 

Where possible, papers and funding applications should be peer reviewed prior to submission, in particular those from junior researchers. 

Role of the Research Integrity Officer (RIO) 

Host Institutions must have a designated member of staff who has responsibility for matters of research integrity within the organisation. Their contact details should be publicly available on the Institution’s website. Their responsibilities could include: 

• Co-ordinating inductions for new starters and group leaders and regular refresher training
• Issuing regular updates to relevant policies
• Acting as a point of contact for anyone wanting to raise research integrity-related queries and for the organisation’s whistleblowing procedure
• Ensuring that policies relating to data archiving are adhered to 
• Orchestrating internal peer review 

Host Institutions must also have a senior staff member responsible for overseeing research integrity. Their contact details should also be publicly available on the Institution’s website. 

Policies Host Institutions should implement to support research integrity

Organisations in receipt of CRUK-funding should hold each of the documents set out below, benchmarked against other reputable research organisations. 

These documents, along with a copy of the Concordat, should be held as a set and be clearly accessible/visible to all staff and students via links on websites or clearly signposted on shared drives. They should be given to all new starters and visiting researchers. Reminders should be sent periodically to all staff so that awareness of the policies, and where they can be found, remains high.  

The key policy documents are:

Code of Good Practice – A document describing the values and behaviours that are expected to be upheld by researchers when undertaking research at the institution. This should include a requirement that researchers conduct their work in accordance with ethical, legal and professional obligations and standards.   

Procedure to Investigate Allegations of Misconduct – A document detailing the various stages that would occur when investigating allegations of research misconduct. This does not need to be a separate document relating specifically to research misconduct, i.e. it can be a procedure that covers a wide range of issues.

Whistleblowing procedure – A policy statement regarding the treatment of whistleblowers under applicable whistleblower protection legislation should be made available to all members of staff and students, outlining;
•    that research misconduct is taken seriously 
•    the process to follow when raising concerns or making a research misconduct complaint 
•    that any student or member of staff with genuine concerns can raise them confidentially without fear of suffering any detriment
•    equally, that disciplinary procedures are in place to deal with malicious allegations.

Data archiving 

Host Institutions should establish clear, consistent data retention policies applicable to, and covering all data generated by, the research undertaken at the institution. All data generated should be subject to these policies. 

It is advisable, and where resource allows, that any raw data and related material (and in particular data relating to published research) is retained according to standard guidance and for a minimum of 10 years after the study has been completed or, in the case of population health and clinical data, a minimum of 20 years. In addition, if image processing is used, a copy of the original image file as well as the manipulated image should be retained. Research based on clinical samples or relating to public health might require storage for longer to allow for long-term follow-up to occur. 

Continuous improvement 

Cancer Research UK believes that the culture of research integrity should be underpinned by a philosophy of continual improvement. Given the constantly evolving world of research, Host Institutions should periodically review processes and procedures to ensure they remain fit for purpose. In addition, Host Institutions should seek opportunities to share their knowledge to foster the development and the dissemination of best practice. 

Host Institutions must produce an annual research integrity statement 

As required by the Concordat, Host Institutions must produce a short annual statement on Research Integrity. This must be presented to their governing body and subsequently made publicly available e.g. on the institution’s website. 

As required by the Concordat, the annual statement must include: 

• A summary of activities to support research integrity 
• A statement to provide assurance that the processes for dealing with allegations of misconduct are transparent, timely, robust and fair 
• A high-level statement on any formal investigations of research misconduct that have been undertaken, including data on the number of investigations 
• A statement on lessons learned from misconduct investigations 
• A statement on how the institution creates a research environment where all staff, researchers and students feel comfortable to report instances of misconduct.

4.2 Responsibilities of the Host Institution to investigate unacceptable research conduct

It is the responsibility of the Host Institution to:

1. Identify a member of staff to act as first point of contact for anyone wanting to raise issues relating to research misconduct at the institution.
2. Carry out an impartial, fair and timely investigation of all allegations of research misconduct made against its staff and students.  The Host Institution must:
   1. protect the rights of all employees involved;
   2. listen and take concerns seriously, and provide appropriate support for both the individual(s) raising the issue, and the respondent(s) against whom the allegation is made;
   3. take appropriate action.

As per CRUK’s Grant Conditions, the Host Institution must have formal written procedures for the handling of allegations of research misconduct made against its staff and students. CRUK recommends that those procedures include:

• A definition of research misconduct that includes, or is consistent with the Concordat.
• Guidance as to who can make an allegation, how to do so and to whom to send it.
• The timescales within which allegations will be dealt.
• The support to be provided to all parties involved. 
• The use of independent external members of formal investigation panels, and ensuring that the investigation is independent and avoids any potential conflicts of interest. 
• The fact that CRUK must be notified of allegations at the earliest opportunity.
• The possible sanctions if the allegation is upheld. 
• How an appeal can be made.
• Procedures for record keeping, including the fact that contemporaneous records of all allegations and investigations must be kept, who is responsible for keeping them and how those records should be kept.
• Provisions to apply to visiting researchers (including students or staff).

The procedures should be developed and reviewed in light of, and be substantially consistent with, the Concordat and the UK Research Integrity Office’s recommended procedure for investigation

4.3 Responsibilities of the Host Institution to report allegations to CRUK 

It is the responsibility of the Host Institution to inform CRUK’s Senior Policy & Governance Manager, Sue Russell via dignityinresearch@cancer.org.uk, in confidence, when a decision is made to formally investigate an allegation of research misconduct.

This applies to any employee or student at the Host Institution who is associated with:

• an application for funding under consideration
• a CRUK grant.

The Host Institution must tell CRUK (in confidence if the information is not in the public domain):

• the name of the person against whom a full investigation has started into an allegation of research misconduct;
• the person’s connection to CRUK (e.g. relevant current or past CRUK grant reference number(s))
• a brief factual statement about the nature of the allegation
• details of any publications or other research outputs affected
• the start date of the investigation and expected/actual investigation completion date.

The Host Institution must:

• Keep CRUK informed during the process of investigation into allegations of research misconduct. We may choose to send a representative to observe any formal inquiry. Investigations should conclude within one year of receiving the allegation;
• Inform CRUK of the outcome of the investigation as soon as it is known; 
• Provide CRUK with the final investigation report.

This should confirm:

• If the allegation was upheld;
• the findings of the investigation;
• if any sanctions are being imposed.

CRUK expects institutions to complete the disciplinary procedure such that a formal finding can be reached, disciplinary procedures are applied and findings are documented.

4.4 Why CRUK asks to be informed and what we do with this information

While CRUK recognises that the requested disclosures under this policy may include personal data, we consider we have a legitimate interest in handling this data. 

During the application stage, CRUK needs to be aware of upheld allegations, so that we can make responsible funding decisions. 

After an award has been made, the Host Institution must tell us when a formal investigation into research misconduct has been started. This is so that CRUK can: 

• monitor that complaints are being dealt with appropriately and in a timely manner; 
• make sure that grantholders receive the support they need, and; 
• be aware of the potential impact on CRUK-funded activities and the steps being taken to manage that impact. 

The information you provide at any point should not include any: 

• sensitive personal information (such as special category personal data, as defined in GDPR) or information relating to criminal offences or convictions;
• personal details about other people, e.g. the person making the claim. 

Any information you send to us will be: 

• handled in confidence and in accordance with data protection law requirements
• stored in a secure, restricted-access location, with access restricted to two members of staff involved in the management of these cases 
• communicated on a need-to-know, restricted-access basis only, where necessary, to pursue our legitimate interests as a funder. This includes making sure that: 
  • grantholders get the support they need from CRUK;
  • the outcomes of CRUK-funded grant activities are not at risk.
• kept by CRUK in line with our retention policy, reviewed regularly to assess whether it can be removed, and for no longer than we need it for our legitimate purposes. Any allegations that are not upheld will be stored for two years after the outcome, the remainder will be stored for six years after the outcome.

4.5 Sanctions 

Research misconduct as defined in this policy covers a broad range of activity of varying severity, therefore any sanctions taken by CRUK in consequence will be on a case-by-case basis. 

Reasonable steps should be taken by the Host Institution to resolve any issues found during the investigation. If the Host Institution or CRUK determines that the allegation of research misconduct is substantiated, we will consider appropriate sanctions. Sanctions may vary in length, depending on the seriousness of the case and any remedial action already in place. These will be independent of any set by the organisation and may include:

• letter of concern
• removal from the application or grant in question 
• withdrawal of current funding.  CRUK will work with the Host Institution to minimise the impact on staff working on the affected grant(s), which may include transferring the grant to another suitable investigator to allow the work to be completed
• restriction from future grant applications
• requiring the withdrawal or correction of pending or published abstracts, papers or monographs produced by the research in question
• requiring the monitoring of future work
• repayment of any grant 

Where allegations of research misconduct are upheld, we expect Host Institutions to implement appropriate disciplinary procedures.

CRUK may apply sanctions against a CRUK-funded Host Institution if CRUK believes:

• the Host Institution has failed to respond to a research misconduct complaint promptly and objectively;
• the Host Institution has failed to keep CRUK informed;
• there has been institutional-level failure to complete disciplinary procedures;
• there has been a serious Institutional-level failure to effectively ensure appropriate good research conduct standards are observed.

Sanctions we apply against Host Institutions may include:

• ongoing monitoring of the Host Institution’s policies and practices;
• not accepting new grant applications from that Host Institution for a period of time;
• suspending funding to the Host Institution in extreme cases;
• taking any further sanctions at its own discretion.

4.6 CRUK’s right to investigate

As stated above, it is the Host Institution’s responsibility to investigate allegations of research misconduct and this is our preferred course of action.

However, CRUK may:

• ask for information about a Host Institution’s processes and how they are effectively implemented;
• check that a Host Institution and any sub-grantee have a policy and are following it.

This may be done as part of CRUK’s standard grants management audits or as part of the annual review process in the case of Host Institutions holding core-funding from CRUK.

If an investigation has been completed and an individual has concerns about the process, CRUK will ask the Host Institution to confirm that it has adhered to its published policy. We are not able to challenge the outcome of the investigation.

Formal allegations, reports of allegations or complaints about process, should be reported to CRUK, as outlined in this policy, and within ten years of the alleged misconduct having taken place.

Where we exercise our right to see the above information, we expect organisations to be able to share it. We strongly discourage the inappropriate use of non-disclosure agreements that might prevent organisations from sharing this information with us.

In exceptional cases, CRUK also reserves the right for it, or its agents, to investigate any aspect of research misconduct itself that concern CRUK-funded researchers (for example, where our reputation is at risk or we are dissatisfied with the investigation undertaken by the Host Institution). 

Any investigations will only be undertaken following consultation with the appropriate representative(s) of the Host Institution.

5. Support & Advice 

For any queries about this policy please contact: dignityinresearch@cancer.org.uk.

• Dan Burkwood, Director of Research Operations and Communications is the senior member of staff who oversees research integrity at CRUK. 
• Sue Russell, Senior Policy & Governance Manager is the first point of contact for CRUK on research integrity matters. 

6. Related documents