Research Ethics
Memorandum to the Membership on Research Ethics and the CPSA
Note: This memo was distributed to CPSA members in early 2008. While it provided a deadline of March 14, 2008 for feedback, comments on this memo or any other aspects of research ethics continue to be welcome.
1. Why a memo on research ethics?
Research ethics and the regulations that govern them play a necessary and important role in the work of Canadian political scientists. This memo has been written in order to provide you, as a CPSA member, with some background on the ongoing review of research ethics regulations underway in Canada at the moment, to articulate some possible concerns from a political science perspective, and to solicit feedback from you on these concerns.
The context for this memo are a series of recent reviews on research ethics that will likely have a significant impact on the way that political scientists conduct research involving human subjects. Two processes in particular are of interest: a review of the place of qualitative research in the Tri-Council Policy Statement (TCPS) on ethical conduct for research involving humans, and the proposals of the Sponsors’ Table for Human Research Participant Protection. In the discussion below, we provide a brief overview of each of these processes and discuss some potential concerns from the perspective of political science researchers.
2. Qualitative Research and the TCPS
2.1 The review currently underway
Many Canadian political science professors and students have had direct experience with the TCPS, as it is the policy that governs all funded research involving human subjects at Canadian universities. The TCPS provides the individual Research Ethics Boards at each university and college with the basis for their assessment of the ethics of research projects conducted by graduate students, for example, or by academics with SSHRC funding. There have long been debates about whether the TCPS, as a document developed by all three research councils and therefore developed in large measure to address the ethical dimensions of bio-medical research, is in fact adequately tailored for the particular demands of social science research. These debates finally led to a review of the treatment of qualitative research in the TCPS by the Interagency Panel on Research Ethics (PRE), which resulted in a report entitled, "Giving Voice to the Spectrum". The most recent document produced by this committee, which served as the basis of consultations this past spring, was "Qualitative Research in the Context of the TCPS".
2.2 Potential political science concerns with the TCPS
The TCPS appears to offer some flexibility in accommodating qualitative research in social sciences. It calls, for instance, for the notion of harm to be interpreted with flexibility, so that the context and nature of research are considered. The notion of minimal risks is also interpreted very broadly so that critical research in social sciences and the humanities which may have a “negative effect on public figures” or “that challenge mainstream thought” are not supposed to be blocked by Research and Ethics Boards. But despite this apparent flexibility some serious concerns about the TCPS and its application by Research Ethics Boards have been raised by social scientists. Four issues can potentially be of concern for research involving human subjects in political science:
i. Defining risk: The vague definition of harm and risk might work against qualitative research insofar as, in the absence of clear definitions, researchers have to imagine what harm there could be, and have to think of worst-case scenarios in terms of risks entailed by the research, even though these worst-case scenarios have very little probability of occurring. Such thinking might deter researchers (including graduate students) to add interviews to their projects.
ii. Anonymity: The principle of privacy and confidentiality might be the most difficult challenge for researchers in political science. The right to privacy and confidentiality is meant to protect the research subjects, while at the same time, the need to conduct research on social issues might require access to personal information. The Tri-Council statement sees the role of REBs as one of balancing the need for research and the privacy of the subjects. This kind of balancing makes sense when researchers study subjects that are vulnerable and that need protection. In political science, it is often the case however that leaders and high public figures are interviewed. And the requirement for anonymity in such cases might undermine the research itself, insofar as the disclosure of personal information about the subjects might be one of the important aspects of the research results.
iii. Power asymmetries: Biomedical models assume that the subjects of the research are vulnerable and that the ethics rules should protect these subjects from harms caused by the researcher. In political science research the research subject may be more powerful than the researcher and effects from the research that the subject may consider harmful, but that hold the powerful figure accountable, may be ethically appropriate. It is not clear that the wording of the TCPS on this issue is adequate to prevent problems for political scientists at the Research Ethics Board level.
iv. Less flexibility: The last point refers to a key challenge for political scientists. On the one hand, the flexibility of the system has allowed for research ethics to take into consideration a series of factors that require exceptions to the rules. But this same flexibility often leads REBs to search for harder and more systematic rules to avoid inconsistencies in their decisions. In such case, the hard rules of biomedical research might become the norm. There is a risk that the Tri-Council policy statement might move towards standardization, and very specific guidelines could replace the vague and flexible system that exists now.
The proposed revisions to the TCPS articulated in the consultation document (link provided above) do go a long way towards responding to many of these concerns. It is not yet clear, however, how many of these proposed changes will in fact be implemented, or how. There has already been some consultation on the TCPS review on qualitative research. We have been told, however, that there will likely be one more round of consultations sometime this winter or early spring.
Finally, it is worth noting that although many political scientists are involved in qualitative research of the kind being addressed by the PRE review, some are also engaged in other forms of research involving human subjects, most notably survey-based research. Those involved in such research have articulated a range of concerns about the TCPS that are not addressed by the current review, including REB concerns about the reliance on telephone contact, their preference for formal, written consent, and their discomfort with retaining data, when this remains essential for long-term analysis of historical trends. For a fuller analysis of these issues, see the CPSA research ethics website.
3. The Sponsors’ Table
3.1 The process currently underway
The Sponsors’ Table is a group of organizations with an interest in research involving humans, including Health Canada, the Canadian Federation for the Social Sciences and Humanities, and Canada’s Research-Based Pharmaceutical Companies, among others. This group is proposing a wide-ranging set of changes to the research ethics governance system - essentially proposing a single national system of oversight for research involving humans. The key report here is "Moving Ahead".
3.2 Potential political science concerns
The Sponsors’ Table is proposing to integrate (and ultimately replace) the existing TCPS process into a single national regulatory framework that would cover all research involving human subjects, whether funded or not, whether conducted at a university or elsewhere, and whatever the discipline. The proposed Canadian Council for the Protection of Human Research Participants (CCRHRP) would have the powers of accreditation, policy setting and education. The idea is not to replace the REBs but rather to add a further level of supervision, by creating a mechanism for accrediting them.
This proposal raises three principal concerns for political scientists:
i. Voice: Given that there are already considerable concerns regarding the smaller voice of social scientists in the TCPS process—one that includes the three granting agencies—it is unlikely that an agency governed by a much larger number of organizations will provide political scientists with much of a say in the policies governing research ethics. Given that 10 of the 15 organizations involved represent medical research, and only two represent social science and humanities research, there is little doubt that the dominant concerns driving the policies and accreditation procedures will be biomedical in nature
ii. A one size fits all approach: Although the Sponsors’ Table report does recognize the concerns of social scientists about the specificity of their research concerns, it also makes it clear that they are seeking to develop a single approach to all disciplines, arguing that “while it is reasonable to argue that the level of scrutiny applied to research should vary by level of risk, it is not reasonable to argue that it should vary by type or discipline” (p. 40). Such an approach appears to move in an opposite direction to the TCPS qualitative review outlined above, and to seek to apply a one size fits all approach to research in Canada.
iii. Extra bureaucracy: Finally, given that the proposal is not to replace existing ethics review processes, but rather to supplement them with an additional layer of bureaucracy, it is likely that this will place additional administrative demands on already-stretched scholars. One might also ask whether the proposed annual budget of $9-10 million dollars is the best way to spend such research dollars.
iv. Relationship with the current PRE review: The relationship between the current review of the TCPS being undertaken by the Interagency Advisory Panel on Research Ethics (PRE) discussed above and the recommendations contained in the Sponsor’s Table’s report, Moving Ahead, is far from clear. It certainly appears that the two processes are moving in opposite directions, the PRE process responding to the particular requirements of research in the social sciences and the Sponsor’s Table and panel of experts seeking to standardize research ethics. This runs the risk of losing much of the significant effort expended in this years-long process, and of forcing the evaluation of research ethics in the social sciences backwards rather than “moving ahead” as the report promises.
We have forwarded our initial comments to the Moving Ahead report to the appropriate authorities. The formal consultation period on this report has passed, but given the scope of the changes proposed, we are hoping that there will be further debate on the subject.
4. What CPSA members can do
If you are interested in these questions, there are several ways in which you can get involved:
• Visit the CPSA ethics website to learn more. We have created a new site dedicated to the issue of research ethics, which provide links to all of the key reports and official documents and to academic research on the subject, and which provides a brief history of the CPSA’s work on research ethics.
• Participate directly in consultations related to these two review exercises. We will be sure to keep you informed of any new consultation processes.
• Review the relevant documents (links provided above) and send us your feedback on the concerns that we have outlined above (cpsa@csse.ca) by March 14, 2008.
• Raise awareness of these issues with your own Research Ethics Board.
5. What we will do
With the help of your feedback to this memo, we plan to communicate CPSA members’ concerns to the appropriate organizations as research ethics guidelines continue to evolve in Canada.
Prepared by the CPSA Working Committee on Research Ethics (Members: Jacqueline Best (Chair), Tony Porter, Hélène Pellerin, Claire Turenne-Sjolander) and approved by the CPSA Board on December 1, 2007.
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