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The need to seek institutional approval to survey staff – was this a misunderstanding of the purpose of Guideline 2.2.13 in the National Statement on Ethical Conduct in Human Research?

 


Katherine (Kate) Christian, Carolyn Johnstone, Jo-ann Larkins and Wendy Wright
Federation University

 

We have conducted a research project investigating the factors contributing to the satisfaction – or dissatisfaction – of early-career researchers (ECRs) from across Australia working in the sciences. A requirement of our ethics approval was a need to provide evidence from every university and research institute of permission to approach their staff to invite their participation in our research.

This requirement was a consequence of answering ‘yes’ to the following question:

If your research involves participants from other organisations (e.g. educational institutions, companies, agencies, collectives), you may need to obtain authorised approval before approaching participants, eg: Department of Education and Training, School Principals, School Councils (for research involving Government schools); Catholic Education Office (Catholic schools); School Boards (Independent schools); Senior Officers (Commercial or Government entities); Elders (Aboriginal communities); or Representative bodies (Collectives). Copies of approval letters must be attached to this application or, if pending at the time of submission, forwarded to HREC when available. Some authorities may decline to provide permission letters until ethics approval has been granted. In such cases, you should submit your application to the HREC for provisional approval pending receipt of the documentation.

Does research involve or impact on participants from external agencies or organisations?  Yes  No

 

 

Our project entailed collection of data from researchers, typically from other institutions, no more than ten years past the award of their PhD who could be participants in a focus group, one-on-one in-depth interviews or in a national on-line survey. The precise method for extending invitations to participants for each of these activities (which included email invitations, social media posts, and advertising by relevant bodies) was specified in the ethics application and approved by our Human Research Ethics Committee (HREC). In most cases email approaches were to be made by third parties, for example distribution of a forwarded email; otherwise email contact was limited to those people whose contact details were known or publicly available.

The eligible population was adult, clearly defined and without special risks; individuals were able to offer informed consent as defined in the overarching principle for consent in the National Statement defined in Section 2.2.1:

The guiding principle for researchers is that a person’s decision to participate in research is to be voluntary, and based on sufficient information and adequate understanding of both the proposed research and the implications of participation in it.

An attempt to meet the requirement to seek approval for people to be invited to take part in the survey from the prospective 37 universities and many independent research institutes was extremely arduous and a significant barrier to recruitment. We question whether seeking this approval added ethical value, and indeed, whether it may have been required because of a misunderstanding of the purpose of the National Statement, in particular of Section 2.2.13:

Within some communities, decisions about participation in research may involve not only individuals but also properly interested parties such as formally constituted bodies, institutions, families or community elders. Researchers need to engage with all properly interested parties in planning the research.

Section 2.2.13 of the National Statement is placed in the section ‘Where others need to be involved in participation decisions’ and appears directly after a section relating to potential participants who lack the capacity to consent. This requirement appears on the documentation of some other Australian HRECs, (including Australian Catholic University, University of Melbourne,  Menzies Research Institute). However, we believe this section of the National Statement is intended to apply to research conducted within organisations and communities that have a duty of care towards people – or groups of people – who are at risk, such as Aboriginal and Torres Strait Islander peoples, school students or adults with special needs.

Alternatively, it could be construed the request to obtain approval is a misunderstanding of the first part of 3.1.16 and that HRECs take the view that the institutions, in their capacity as employers, have a duty of care as ‘gatekeepers’ for their employees.

Researchers and reviewers should consider the degree to which potential participant populations might be over‑researched or may require special consideration or protection and the degree to which the flow of benefits to that population (or to individual participants) justify the burdens.

The latter part of this section suggests that individuals within the ECR population that we were attempting to sample could have been permitted to make up their own minds about participation, as they do not fall into the type of special category suggested.

Equally, people should not be denied the opportunity to exercise self-determination or obtain the potential benefits of research solely because they are a member of a population that might be over-researched or may require special consideration or protection, such as Aboriginal and Torres Strait Islander peoples.

The literature about the work-life of ECRs in STEMM disciplines in Australia does not show evidence of an over-researched ECR population or a group which merits special consideration. We are aware of only two national surveys of Australian ECRs in STEMM in recent years (Hardy, Carter, & Bowden, 2016, Meacham, 2016).

If any university staff member received an invitation to participate from an external researcher, whether directly or forwarded from an internal address, it is unlikely they would have wondered if either the researcher, or they, needed permission from the organization. Instead, they would make an individual decision on participation or otherwise, and act accordingly.

We used several recruitment strategies. Since all the potential participants worked at universities and research institutes, a direct approach to these entities provided the logical and, indeed, preferred avenue. Organisations and associations whose members were likely to represent the target audience were also approached; these ‘umbrella’ groups were very supportive ofrequests for assistance with recruitment of participants and, more generally of the research. They extended an invitation to their members on behalf of the project team via broadcast email and social media. Another HREC-approved method of recruitment was via social media. Social media, which has no boundaries, proved itself to be a successful avenue for recruitment and due to its very nature and culture of sharing brought in responses from prospective participants based at many universities from which we had received no response to our initial request for approval to recruit their staff. Such responses did not violate ethics requirements, again bringing into question the merits of seeking institutional approval.

We did not interpret the requirement to obtain approval as being necessary for the ‘umbrella’ organisations as they do not have the same responsibility for, or duty of care to, the ECRs. This highlights another anomaly in the interpretation of the guidelines: what constitutes ‘an organisation’ from which approval might be required? So saying, we interpreted the ready agreement of these organisations to share the invitation, whether by distributing the link by email or by promoting it on social media, as implicit approval.

We recommend that HRECs amend their forms to permit researchers to offer further explanation about the nature of the people being recruited and their capacity to freely make a consent decision so that the Committee members can make appropriate decisions about the need for institutional approvals. We argue that these approvals should only be required when the research participants need a particular level of protection.

References

Hardy, M. C., Carter, A., & Bowden, N. (2016). What do postdocs need to succeed? A survey of current standing and future directions for Australian researchers.2, 16093. https://doi.org/10.1057/palcomms.2016.93

Meacham, S. (2016). The 2016 ASMR Health and Medical Research Workforce Survey. Australian Society of Medical Research.

Contributors

Katherine Christian, Federation University Australia School of Arts, Mt Helen Campus, Ballarat, Victoria

Carolyn Johnstone, Federation University Australia School of Arts, Mt Helen Campus, Ballarat, Victoria

Jo-ann Larkins, Federation University Australia School of Science, Engineering and Information Technology, Gippsland Campus, Churchill, Victoria

Wendy Wright, Federation University Australia School of Health and Life Sciences, Gippsland Campus, Churchill, Victoria[MI3]

Sources

Menzies Research Institute
https://www.menzies.edu.au › Research › Forms › HREC_Application_Form

Australian Catholic University
https://www.acu.edu.au/research/research-ethics-integrity-and-compliance/research-ethics
https://www.acu.edu.au › assets › Ethics_Guidelines_revised_March_2012

University of Melbourne
https://staff.unimelb.edu.au/__data/assets/pdf_file/0009/1977543/HRE-Application-Guidance-V-1.1.pdf

This post may be cited as:
Christian, K., Johnstone, C. Jo-ann Larkins, J. and Wright, W. (17 September 2019) The need to seek institutional approval to survey staff –was this a misunderstanding of the purpose of Guideline 2.2.13 in the National Statement on Ethical Conduct in Human Research?. Research Ethics Monthly. Retrieved from: https://ahrecs.com/human-research-ethics/the-need-to-seek-institutional-approval-to-survey-staff-was-this-a-misunderstanding-of-the-purpose-of-guideline-2-2-13-in-the-national-statement-on-ethical-conduct-in-human-research



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