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Past Interpretations of the TCPS

Subject Consent Procedures for Research in Schools, and Complaints About Research Projects
Keywords schools, consent, accountability, responsibility, role of REB, role of PRE, role of the Agencies, role of institutions, public school REBs, complaints
TCPS Articles 1.14, 2.1
Date June 2004

PDF Consent Procedures for Research in Schools_June 2004.pdf

1. Thank you for your question about research that university students conducted in a public school. This research, which was done in your son’s school in the context of a university practicum, involved some one hundred children, and no parental consent was obtained. You ask whether public school boards have to establish Research Ethics Boards (REBs). You also ask if the Interagency Advisory Panel on Research Ethics (PRE) has a complaint process, and how an individual can lodge a complaint against an institution such as a university or school board. Your inquiry has been referred to the Interagency Advisory Panel on Research Ethics (PRE) for advice1.

2. While consent is generally required for research conducted under the auspices of institutions that have adopted the Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans (TCPS)2, a breach of such standards raises issues largely beyond the responsibilities of PRE. PRE does not process research ethics complaints. You could pursue these questions with your school board and the university involved in the research you describe.

3. Review of research ethics at the school level is also beyond the scope of PRE. You may inquire about this with your school board or the Ministry of Education.

Role of PRE

4. PRE is a body of external advisors established in 2001 by Canada’s three federal granting agencies: the Canadian Institutes of Health Research (CIHR), the Natural Sciences and Engineering Research Council of Canada (NSERC), and the Social Sciences and Humanities Research Council of Canada (SSHRC). PRE, supported by the Secretariat on Research Ethics (SRE), provides interdisciplinary, independent advice to the agencies on the evolution of their joint research ethics policy, the TCPS. PRE’s responsibilities include responding to requests for interpretation of the TCPS. PRE does not get involved in enforcement, regulation, compliance, processing of complaints or appeals, etc.

Agency and Institutional Roles: Adherence to the TCPS

5. The TCPS describes ethical norms for research involving humans. Most of its users are the universities, hospitals and colleges that receive funding from the agencies and that have agreed3 to abide by the TCPS. Responsibilities for adherence to the TCPS are shared between the funders (the granting agencies) and the recipients (the institutions and researchers). This does not involve PRE. As the commentary to article 1.14 of the TCPS says, “an institution is responsible for the ethical conduct of research undertaken by its faculty, staff or students regardless of the location where the research is conducted.” This would normally apply to university researchers working in community settings, such as schools.

Consent Issues

6. The TCPS generally requires that researchers obtain the free and informed consent of participants before undertaking “research involving humans”4.There are some narrow exceptions5 to this, and one purpose of ethics review before a research project begins is to determine whether any exceptions are justified. This is why most universities have created interdisciplinary Research Ethics Boards (REBs) to conduct an initial ethical review of proposed research—to consider issues such as informed consent, and to review ongoing research. Some institutions6 have developed guidelines for conducting research in schools. Your correspondence did not indicate whether the university’s REB had reviewed the research in question.

University Accountability for Human Research Ethics

7. Within the university structure, human research ethics is often a responsibility of an administrator such as the vice-president of research. In universities that have adopted the TCPS, the development and implementation of an institutional research ethics policy, as well as the creation and operation of institutional REBs, are also typically part of this responsibility. While the human research ethics policy and REB review in a university should be consistent with the TCPS, the university is responsible to oversee their implementation. This would include oversight of REB review of specific research projects.

8. Therefore, questions or complaints about research conducted through a university should be directed to that university. When the conduct of a university researcher raises questions of research misconduct or integrity, complaints can be filed with both the university and one of the Agencies, under the Tri-Council Research Integrity Policy7.

Public School REBs

9. You ask whether public school boards in Ontario are obliged to establish REBs. We are unable to answer this, because it falls beyond our knowledge and mandate. Perhaps your school board or the Ministry of Education could respond. The TCPS does not require school boards to establish REBs. However, some public school districts have implemented parallel review processes. An example is the Ottawa-Carleton District School Board’s advisory committee that reviews applications from researchers wishing to conduct research in schools8.

We hope you find this information useful.

Sincerely,

Secretariat on Research Ethics,
on behalf of
The Interagency Advisory Panel on Research Ethics
pre.ethics.gc.ca


  1. PRE provides advice on such interpretation questions to assist the research ethics community in applying the TCPS to the ethical issues it faces. While responses to TCPS interpretation questions may address ethical dimensions of legal issues in research ethics, PRE does not provide legal advice. Nor does it act as an appeal body on REB or institutional decisions.
  2. Official version online at: http://pre.ethics.gc.ca/eng/archives/tcps-eptc/
  3. Institutions that formally adopt the TCPS sign, with the Agencies, a Memorandum of Understanding on the Roles and Responsibilities in the Management of Federal Grants and Awards. Available at www.nserc.gc.ca/institution/mou_doc_e.htm
  4. See article 2.1(a) of the TCPS.
  5. See, for example, article 2.1(c) of the TCPS.
  6. http://www.research.uwaterloo.ca/ethics/human/ application/schoolResearch.htm
  7. Tri-Council Policy Statement: Integrity in Research and Scholarship http://www.sshrc.ca/web/about/policies/integrity_e.asp
  8. Ottawa-Carleton District School Board, Research Guidelines. Available at http://www.ocdsb.edu.on.ca/general_info/research_guidelines.htm