A. Purpose
This policy aims to establish principles, practices, scope, and procedures to guide and ensure the ethical conduct of research and scholarship involving human participants carried out under the auspices of the Adler Graduate Professional School Inc., Toronto.
Furthermore, this policy aims to foster a research environment and, by extension, a professional practice environment in which the following core ethical principles from the Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans, 2nd Edition (TCPS2, 2018) are foundational:
Respect for Persons
“…recognizes the intrinsic value of human beings and the respect and consideration that they are due.”
“…incorporates the dual moral obligations to respect autonomy and to protect those with developing, impaired or diminished autonomy.”
Concern for Welfare
“The welfare of a person is the quality of that person’s experience of life in all its aspects.”
“…means that researchers and REBs should aim to protect the welfare of participants, and, in some circumstances, to promote that welfare in view of any foreseeable risks associated with the research.”
Justice
“Justice refers to the obligation to treat people fairly and equitably.”
“Fairness entails treating all people with equal respect and concern.”
“Equity requires distributing the benefits and burdens of research participation in such a way that no segment of the population is unduly burdened by the harms of research or denied the benefits of the knowledge generated from it.”
B. General Principles
All research and scholarship will be carried out in accordance with the Tri-Council Policy Statement-2, Access to Information and Privacy Legislation, human rights legislation, and any requirements that may be established by funding agencies, research partners, and/or other contractual agreements with other organizations.
C. Scope
This policy applies to all students, faculty, staff, and other approved individuals who conduct research involving human participants under the auspices of the Adler Graduate Professional School, Toronto.
Research involving animals as participants cannot be carried out under the auspices of the Adler Graduate Professional School Inc. and, therefore, is not included within the scope of this policy.
D. Ethics Review Required
All faculty, staff or students of the Adler Graduate Professional School who wish to engage in research and scholarship involving human participants, including self as a participant, are bound by this policy and are required to receive approval from the AGPS Research Ethics Board before embarking on any and all research activity. This requirement also applies to those with affiliations not noted above who wish to recruit participants through AGPS and/or conduct research on the AGPS property.
A full ethics review is required for all research that involves any form of data collection from humans, including all research that falls under the guidelines for course-based research and research involving the collection or testing of biological substances (e.g., human remains, tissues, fluids, etc.).
An ethics review is not required for research that is conducted about a living individual involved in the public arena that is exclusively based on publicly available information or for quality assurance studies, performance reviews, testing within normal educational requirements or projects with community partners that involve data collected for the purposes of supporting the development or provision of the partner’s services.
E. Authority and Mandate of the AGPS Research Ethics Board
The AGPS Research Ethics Board (REB) is empowered with the responsibility to review, approve, reject, propose modifications to or terminate any proposed or ongoing research involving human participants that is conducted within or by AGPS students, faculty, staff, and other approved individuals. The VP Programming of AGPS will establish the REB, define appropriate reporting relationships and provide the necessary funds and administrative support that enable the REB to fulfill its duties.
The REB will consider and decide upon initial applications for ethics review that involve research with humans, including projects that do not involve direct data collection from humans (e.g., observational studies). The REB will also conduct continuing ethics review of research projects. (See “Continuing Research Ethics Review” below).
In order to ensure the integrity of the ethics review process and oversight of research and scholarship conducted within the scope of this polity, the REB will maintain an arm’s length relationship to faculty, students, and staff, as well as other approved individuals whose research applications it is required to review. The TCPS2 specifies: “The highest body within an institution shall: establish the REB or REBs; define an appropriate reporting relationship with the REBs; and ensure the REBs are provided with necessary and sufficient ongoing financial and administrative resources to fulfill their duties. REBs are independent in their decision making and are accountable to the highest body that established them for the process of research ethics review.” [TCPS2, Article 6.2]
F. REB Membership
The Adler Graduate Professional School will maintain a REB that consists of at least five members and includes:
- representation across the gender spectrum,
- representation that reflects social and cultural diversity,
- at least two members that have subject matter and research methodology expertise in psychology or related disciplines,
- at least one member knowledgeable in ethics, and
- at least one member from the local community served by the AGPS, who has no official role with AGPS. The purpose of the community member is to represent the interests of participants.
The AGPS VP Programming will appoint members of the REB. Membership of the REB will be reviewed on an annual basis.
The AGPS VP Programming will appoint or designate a Chair of the REB whose responsibility is to manage the activity of the REB to ensure the ethics review process conforms to the requirements of this policy and the TCPS2 and to facilitate REB meetings.
Substitute REB members may be designated in the event that a REB member is unable to fulfill their responsibilities as necessary.
A quorum of the REB is required for meetings to consider applications for research that involves more than minimal risk. To meet quorum, members will possess the relevant expertise, knowledge and competence related to the methodology, research ethics and laws related to the applications under consideration. The Chair or designate will ensure that quorum is met. When there is less than full attendance, decisions requiring full review will be adopted only when the members in attendance at that meeting have the specific expertise, relevant competence and knowledge necessary to provide an adequate research ethics review of the proposals under consideration.
G. General Process for Ethics Review and Approval Decisions
All AGPS researchers seeking approval of their research projects will submit an application for ethics review to the REB. Applicants will demonstrate alignment of their proposed research with the principles set out in the TCPS2 and as outlined in the Purpose section of this policy. AGPS’s REB Application for Ethical Review of Human Participant Research (REB Application) is designed to ensure that applicants meet the requirements of the TCPS2 and this policy.
H. REB Ethics Review and Decision Process
a. Full REB Ethics Review and Decision
A full REB ethics review is the default process for all research that involves the collection of data from human participants. The REB will complete a full ethics review of all research applications that involve the collection of data from human participants, even in cases where the project involves only minimal risk.
A person who falls under the scope of this policy will submit a REB Application to the REB Chair and/or REB Coordinator according to current procedures outlined in the REB Ethics Review Application form (the “Applicant”).
The REB will schedule in-person meetings once a month for at least nine months per year when school is in session to review and decide on all ethics review applications accepted for that month.
The REB will use a consensus model of decision-making, meaning that all members of the REB will agree upon and be prepared to uphold the final decision to approve, reject or recommend changes to submitted research applications. Differences in perspectives are to be discussed until a decision is reached. In the event that consensus cannot be reached, the Chair or designate can institute a voting process to reach a decision.
REB decisions include:
- Ethical approval is granted without any modification.
- Ethical approval is granted with an expectation of modifications. The Applicant is required to submit modified documentation per expectations to the Chair or designate of the REB, who will be empowered to review the submission and provide final approval.
- Ethical approval cannot be granted without significant modifications to the research application to address REB concerns. The Applicant will make necessary modifications and re-apply for REB approval based on the modified application.
- Ethical approval cannot be granted, and the proposed research cannot be modified to resolve the concerns of the REB. Reasons for refusal will be communicated to the researcher and their supervisor and documented in the REB files. See “Reconsideration” below.
b. Delegated Panel Ethics Review and Decision
At the discretion of the REB Chair, where minimal risk of the proposed research is apparent, the Chair may assign one or more members of the full REB to conduct a delegated ethics review. An individual or panel delegated for review is empowered by the Chair to conduct the ethics review on behalf of the full REB. The Chair or an appointed designate will report on the outcome of the delegated ethics review to the full REB. The designate may refer the application to the full REB for review.
c. Reconsideration
An Applicant has the right to request, and the REB has an obligation to provide, reconsideration of any decision. To request reconsideration, the Applicant will submit a letter, in writing, to the REB Chair asking for reconsideration, stating the reasons why reconsideration and a different REB decision is warranted. Requests for reconsideration will be reviewed at the next scheduled REB meeting. The REB will grant one reconsideration per application.
d. Appeals of Reconsideration
Where the Applicant has exhausted all her/his options for reconsideration of an unsatisfactory decision, the Applicant may appeal the REB reconsideration decision to the AGPS VP Programming.
Upon receiving a request for an appeal from an applicant, the VP Programming will appoint an ad hoc appeal committee comprised of individuals that reflect the range of expertise and knowledge of the standing REB that relates to the topic of the research under review. The VP Programming cannot serve on the Appeal Committee, nor can members of the standing REB committee whose decision is to be reviewed.
The Appeal Committee will have the authority to review a decision by the REB. In so doing, it may approve, reject, or request modification to the research application. The Appeal Committee’s decision, on behalf of AGPS is final.
If the VP Programming is in a position of real, potential, or perceived conflict of interest in relation to the formation of the Appeal Committee, then the Appeal Committee will be formed by another party, such as the President, Chair of the Faculty Council, or a Program Director who is not involved in supervising the research under appeal.
e. Continuing Research Ethics Review
The Applicant will include, at a minimum, a plan or monitoring process for continuing ethical review appropriate to the proposed research. If projects take longer than one year to complete, the Applicant is required to provide an annual report to the REB confirming that research is proceeding as initially approved and provide prompt notification when the project has concluded. The REB’s level of monitoring for ongoing research will be commensurate with the proportionate approach to ethics review.
I. REB Notification and Record-Keeping Process
The Chair of the REB will be responsible for recording outcomes of REB reviews and notifying the Applicant of the results. The Chair may designate this responsibility to REB members and/or the REB Coordinator as necessary for the efficient management of the REB process.
The REB will notify the Applicant of the REB decision in a timely manner, ideally within one week of full REB meeting and decision.
Documentation regarding research ethics decisions will be placed in the REB file archives. Copies of documentation related to ethics applications from AGPS students, including approval certificates, will additionally be maintained in the central student files at AGPS by the Registrar.