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Guidelines for ESOP and Research Integrity Review

Background

The UNC-CH Policy and Procedures on Responding to Allegations of Research Misconduct (the “Research Misconduct Procedure”) clearly defines steps, identifies who should be involved, and how to report allegations of research misconduct. https://policies.unc.edu/TDClient/2833/Portal/KB/ArticleDet?ID=132346  To provide some guidance to the ESOP faculty and staff for personnel management when a research integrity incident arises, the following guidance should be applied.

Proposed ESOP Research Misconduct Management Process

  1. When a UNC ESOP faculty, staff, or student identifies a potential research integrity issue, that individual should immediately inform their supervisor. The supervisor is required to inform the Department Chair, Director of Compliance and the Associate Dean of Research and Graduate Education (“Required Notifications”). If the supervisor is the subject of the possible violation, they should inform the Required Notifications. These individuals will notify the Institutional Research Integrity Officer (the “RIO”) and initiate the Research Misconduct Procedure.
  2. The Research Misconduct Procedure is designed to afford all persons who may be in violation an appropriate and unbiased due process procedure to evaluate the situation. Once the issue has been reported to the individuals in Step 1, all subsequent actions should be done with a focus on risk management and without assuming that any outcome is predetermined.
  3. No action should be taken with respect to the employment or job responsibilities of the subject(s) in question that would imply a predetermined outcome and could create liability for the School. Once the RIO has been engaged, he/she will start the review of the incident and will work directly with IT, HR and any other ESOP teams as needed in order to secure all data, electronic communications and determine any immediate actions that need to be taken with respect to the subject(s) to ensure the continuation of an appropriate work environment for all impacted employees that also minimizes the possibility of School liability.
  4. In the event the incident creates an environment where there is a danger to the individual(s) in question or to other employees or staff, to any animals or to property, action can be taken to remove this threat in consultation with the RIO, HR and, if necessary, University Security.
  5. Once the investigation is complete, the RIO will provide a summary and a recommendation for any action to the Dean. A copy of this summary and recommendation will also be provided to the subject(s) of the investigation. Once the report is delivered to the Dean, the Dean will make a final decision on what course of action, if any, should be followed.

If the above guidance is followed in all cases of suspected violations of research integrity, the RIO will make recommendations within approximately 3 months from the start of the Research Misconduct Procedure. A focus on ensuring the subject(s) has due process as part of the investigation will minimize the potential for School liability with respect to general HR or EEO issues. No actions should be taken that imply a presumption of guilt prior to the completion of the Procedure. If any faculty, staff, or students have questions or need guidance, they should consult the Director of Compliance.