SACAP REC Whistleblower Form
Reporting Research Misconduct at SACAP
Whistleblowers can choose to make a report anonymously. Providing the name and contact details of the whistleblower is not a requirement for reporting. Should no name and contact details be provided, however, the whistleblower can not be contacted for further clarity, consultation or resolution of the case and entrust the Chair of the REC to see the case to resolution on their behalf.
What is Whistleblowing?
In the context of research ethics, whistleblowing is defined as the act of informing someone in authority about alleged research misconduct, fraud, maladministration and non-adherence to approved research procedures, guidelines or policies occurring at the institution. The alleged acts have to be related or incidental to the execution of research and include:
- Misconduct: Involves intentional deception during research conduct through fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results. Fabrication is making up research data or results and recording or reporting the fabricated material. Falsification is manipulating research materials, equipment, or processes, or changing or omitting data or results such that the research is not accurately represented in the research records. Plagiarism is the appropriation of another person’s research idea, processes, results, or words without giving appropriate credit. Misconduct furthermore relates to any infringement of the guiding principles of ethical research, obligations of researchers towards human participants or animals, regulations relating to consent. Please note that honest errors/differences of opinion/disagreements are not research misconduct.
- Fraud: Involves actions or behaviour like dishonesty, deception or forgery by an individual, other person or entity that manipulate others or systems into providing a benefit that would not normally accrue to that person
- Maladministration: Is the act or process of running a system or organization incorrectly either through inefficiency, incompetence or dishonest administration, as it relates to research practices. This could include failure to take any action, failure to provide correct or complete information, inadequate record-keeping, making misleading or inaccurate statements, inadequate liaison and consultation.
- Non-adherence to approved research procedures: Ethical approval is given with the condition that the research is conducted strictly in accordance with the methods and procedures set out in the approved application. Additionally, it is the principle researcher’s responsibility to ensure that all researchers associated with the project are aware of the conditions of approval and that the SACAP REC Office is immediately notified of a) any changes that can affect the study-related risks for the research participants and any potential ethical implications b) any adverse circumstances or complaints that arise during the undertaking of this research project as well as c) any other unforeseen events or unexpected developments that merit notification.
Conflict of interest: is not classified as research misconduct, however, it could undermine the integrity and trustworthiness of the research. Conflicts of interest should always be declared, as well as the precautionary measures that will be taken.
Reporting Research Misconduct at SACAP
The purpose of this form is to allow whistleblowers (i.e. members of the SACAP REC, SACAP employees, SACAP students, research participants or members of the public) to raise concerns with the Chair of SACAP REC’s regarding concerns with ongoing research with the SACAP RECs ambit. The whistleblower must have reasonable grounds to believe that there is 1) misconduct 2) fraud 3) maladministration or 4) non-adherence to approved research procedures, guidelines or policies committed by a researcher of SACAP in respect of research.
Additionally, this form ensures confidentiality to all whistleblowers and furthermore ensures that nobody would be exposed for disclosing, in good faith, information that would assist the Chair of the SACAP REC in meeting their obligation in terms of the guiding principles and regulations as set out by the National Health Research Ethics Committee and Department of Health.
SACAP is committed to the highest standard of ethics and integrity in research. Researchers of the institution are expected to behave in an honest and responsible way at all times. Research activities will be carried out in an open and transparent manner and in accordance to the code of conduct for SACAP researchers stipulated in the Policy on Research Ethics and the Policy on Academic Integrity.
Any whistleblower who has a reasonable belief that any act of misconduct, fraud maladministration, or non-adherence to approved research procedures, guidelines or policies has been committed, is obligated to report any such unethical research practices.
Procedure
- A disclosure should be made in writing using the official complaint form enclosed, which is submitted to the SACAP REC Office for the attention of Chair of the SACAP REC. When a member of the SACAP REC, a staff member, student of the college or research participant makes a disclosure to the applicable REC Chair, it must be done in a responsible and honest manner. Whistleblowers may choose to remain anonymous at the time of reporting, however, this will forfeit their right to be included in consultations and resolutions as indicated below.
- If the notification is made to the REC Chair, they must as soon as possible acknowledge receipt of the disclosure directly to the whistleblower and immediately (within three days) notify the committee.
- The REC Chair will immediately, upon receipt of the disclosure, set up an appointment with the whistleblower and legal representative of the REC (investigating team) within 14 (fourteen) working days of the acknowledging of the disclosure.. The aim of this appointment is to allow the investigating team to conduct an initial investigation in order to establish whether there is a prima facie case to answer.
- If the investigating team considers that there is a prima facie case to be answered, the way forward is discussed to the satisfaction of all members. If disciplinary measures are required, the Chair of the SACAP REC will follow the appropriate college procedure, involving reporting to the relevant persons responsible.
- Investigations will be dealt with sensitively, on an impartial basis and within a reasonable time frame. Details of the allegation, the identity of the person making the allegation and against whom the allegation is made will remain confidential. The REC Chair and legal representative of the REC can request the assistance of an independent person. Those requested to assist in the investigation will be chosen on the basis of being independent from the issues/events from which the allegation has been initiated. The Academic Dean of the College is notified of the reporting and the actions taken. If necessary, the Dean is included in the actions.
- If the whistleblower is not satisfied with the outcome of the investigation, they should raise their concerns with the Dean of the College to find another solution or to refer them to a higher authority.
- The NHREC is notified of the complaint, actions and or resolutions.
To report 1) misconduct 2) fraud 3) maladministration or 4) non-adherence to approved research procedures, guidelines or policies committed by a researcher of SACAP in respect of research, please complete the following form: