Section 1 - Introduction
(1) These Guidelines support the University's commitment to the recruitment of participants for research involving humans being conducted in a safe and ethically responsible manner and in accordance with the requirements of the National Statement on Ethical Conduct in Human Research.
(2) The Guidelines provide advice on:
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- the use of University branding on recruitment material,
- contacting organisations, institutions or businesses for research recruitment purposes,
- the recruitment of University of Newcastle students and staff for research,
- the recruitment of students from New South Wales schools for research,
- the recruitment of participants in public spaces,
- witnessing a participant's signature, and
- the reimbursement of research participants.
Section 2 - Intent
(3) The provisions of this document relate to the recruitment of human participants for research at the University of Newcastle.
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Section 3 - Instructions
Part A - Use of University Branding on Recruitment Material
(4) In the light of policies on University branding and clear identification of the institution, the Human Research Ethics Committee expects that University letterhead, appropriate to the school/college/centre of the Chief Investigator or project supervisor, will be used on recruitment material when research is being conducted by staff or students of the University.
(5) Researchers need to ensure that they are complying with the University's corporate standard where the University logo is used in any form. For more information please refer to the University's Corporate Identity Policy and Corporate Identity Guidelines.
(6) In some cases, where a researcher has a dual role with the University and another institution or research centre, e.g. University and Hunter New England Health, it may be appropriate to use a joint letterhead which supports the logos and identities of both institutions, or use the letterhead of the other institution or research centre.
(7) As a minimum requirement, the Human Research Ethics Committee requires acknowledgement of the University relationship in the opening paragraph of all research participant information statements. In the case of research being conducted by students, this must extend to a statement which identifies the project as the research of a particular student(s), the course of study and the supervisor(s).
(8) The Human Research Ethics Committee or other relevant delegated authority is obliged to monitor approved research protocols including the use of recruitment material. One of the measures in place to assist the Committee with its monitoring obligations is that the University's Ethics Officer (Human) is responsible for receiving complaints from participants.
(9) To avoid ambiguity, the independent contact for complaints should be the University's Ethics Officer (Human) when University letterhead is used, and the Manager, Research Ethics and Governance when any letterhead of Hunter New England Health is used. Where Hunter New England Health is not involved, the University's complaints contact should be in addition to any other organisation's complaints contact.
Part B - Contacting Organisations, Institutions or Businesses for Research Recruitment Purposes
(10) This section outlines the procedures to be followed by University researchers when seeking to involve organisations, institutions or businesses in research projects.
(11) These guidelines apply to two primary types of external organisation involvement:
- the distributor model - where the organisation is solely a conduit to potential research participants
- the organisational case study or workplace research model - where the organisation is itself the subject of the research; and
- a mixed model with features of both.
Models of External Involvement
Distributor Model - A Conduit to Potential Participants
(12) In the distributor model of external involvement the organisation is not the subject of the research.
(13) The organisation is used only to provide access to potential participants by distributing participant information statements, consent forms and/or surveys, etc.
(14) This model can provide access to a large potential participant pool of staff, customers or members.
(15) Participation in the research is voluntary.
Organisational Study or Workplace Research Model
(16) In the organisational model, the organisation is the subject of the research.
(17) Researchers may be seeking, for example, to investigate aspects of the organisation's performance, management, occupational health and safety practices/standards; staff satisfaction or attitudes.
(18) Employee participation in this model may be voluntary or be directed by the organisation. The latter is most common in research initiated by the organisation.
(19) In the mixed model:
- Some aspects will be from the Organisational Study model e.g., investigation of management practices, and
- Other aspects will be from the Distributor model e.g., client participation coordinated by the organisation.
Timing and Type of Approach
(20) The type of model used: 'Distributor' or 'Organisational Study' will have ramifications for the timing and type of initial approach to the organisation by the researcher.
(21) Timing of approach:
- An approach should be made to the organisation prior to the submission for Ethics Approval, to ascertain the organisation's willingness to assist with the research.
- Researchers should ensure that the organisation is willing to distribute invitations or other material, e.g., via email or as hard copies to be left in a staff room. Please note that there is little point in submitting an application to an organisation with policies that preclude distributing surveys to people.
- Written indication (e.g., an email) of support from the organisation should be provided with the ethics application.
- The organisation must be advised that the research will not proceed until reviewed and granted ethics approval.
(22) Type of approach:
- An approach can be informal, e.g. via email, but must be directed to a person in the organisation who has the authority to make that decision and is in a position to distribute, or direct the distribution of participant information statements, surveys, consent forms, etc.
- The researcher should never ask the organisation to provide the names or details of potential participants without the prior consent of the individuals involved. The only exception occurs if the information is in the public domain, e.g. the membership lists of some associations which are publicised.
- Equally, a researcher must not advise the organisation of who has or has not participated.
Organisational Study Model
(23) Timing of approach:
- An informal in-principle agreement to participate in the research may be obtained from the organisation prior to an ethics application.
- However, formal, written approval must be obtained after all relevant documents have been granted ethics approval and have been sighted by the organisation.
(24) Type of approach:
- The formal approach to the organisation must be: (i) in writing; (ii) addressed to a person with the appropriate authority in the organisation; and (iii) accompanied by documents which have been granted ethics approval and already sighted by the organisation.
- The accompanying documents should provide all necessary details including who is eligible to be a participant and what will be required of them.
- In addition, the organisation must be provided with an information statement setting out the research, details of the organisation's involvement, and a consent form for signing.
Issues to Consider
(25) Potential participants must be made aware of method of contact.
(26) The information statement for participants approached via an organisation must state how they have come to receive the invitation to participate in the research. For example, “You are being invited to participate in this research because you are a member of the Master ** Association (M**A). The M**A is distributing this invitation to its members on behalf of the researchers and has not provided any information about you to the researcher.”
(27) Protection of organisational contacts
- An individual's decision must be informed and freely given. Recruitment methods should ensure this. Where participation is voluntary, i.e., not directed by their employing organisation, future contacts between potential participants and the researchers should be direct i.e. not through the organisation.
- The information statement must:
- assure recipients in the study that the organisation will not be advised as to who participates, and
- explain how potential participants can contact the researchers for further information or to return surveys, consent forms, etc.
- Face-to-face activities, e.g., interviews or focus groups, should ideally be held at a venue other than the organisation's premises. This is particularly important if participants are asked to comment on organisational practices or their relationship with the organisation and could be disadvantaged if the organisation was aware they had participated.
- When possible, participants should be able to contribute to the research anonymously; identifying information should therefore not be collected. Survey research, unless it has a follow-up phase, or there is a duty of care to respond to information collected, should not ask for identifying information. It then does not need a consent form. Consent is implied by participating, i.e., participants receive full information about the research and what it involves and indicate their consent by completing and returning the survey.
- Feedback of results to participants can be catered for by either:
- publishing a summary of the results via the organisation's newsletter or company bulletin;
- posting a summary on a web site participants can access;
- providing them with a Request for Summary of Results form which they can return separate from the anonymous survey; or
- providing an e-mail address for them to lodge a request for a summary.
(29) Traveling overseas to conduct research
- Research data collection may be undertaken outside of Australia without researchers needing to travel outside of the country e.g. an on-line survey administered from Australia. Where participants are located outside of Australia and researchers travel overseas to conduct the research, it may be necessary to obtain approval to travel.
- Researchers planning to travel overseas to conduct research need to check the Department of Foreign Affairs and Trade website Smart Traveller, for any travel advisories or warnings that apply to intended travel destinations. Where the country you intend to conduct the research is Level 3 or 4 you will require the approval of the Vice-Chancellor or Deputy Vice-Chancellor (Research) to travel. Please refer to the Health and Safety web site for further information.
- Please note that where the intended travel destination is Level 3 or 4 and approval to travel is required a letter or e-mail from the relevant overseas institution/organisation to the researcher will be required demonstrating agreement 'in principle' to research being undertaken within/through the organisation subject to full human ethics approval being granted. A template has been provided (Appendix One – see Associated Information) which provides an approved format for requesting this 'in principle agreement' prior to ethics approval being obtained.
Part C - Recruitment of University of Newcastle Students and Staff for Research
(30) In cases where participants will be the staff and/or students of the University of Newcastle, for the purposes of research rather than quality assurance, please note the following:
- All research activity involving students and staff requires the prior approval of the Human Research Ethics Committee or other relevant delegated authority.
- Please refer to the Human Research Ethics Committee Quality Assurance Guidelines for advice on quality assurance activities.
(31) Teaching time may be used for appropriate evaluation of courses, programs, services and functions of the University.
(32) Where there is a clear educational benefit to the students involved, research activities may be conducted in class time with the prior approval of the Head of School, following consultation with the Course Co-ordinator, where appropriate, and lecturer.
(33) It is acceptable for students to be approached after the end of a class, for the purposes of introducing a research project and inviting their participation, with the prior approval of the Head of School, Course Co-ordinator where appropriate, and lecturer;
(34) Where students are being approached during or after the end of a class, there is to be no coercion from academic staff involved in the teaching unit. The introduction of the research project to students is to be undertaken by a person who does not have teaching and/or assessment responsibilities for those students, and students are advised of their right not to participate.
(35) External researchers seeking access to students and/or staff for participation in research will require organisational approval from the University of Newcastle.
Part D - Recruitment of Students from New South Wales schools for Research
(36) Where research participants will be drawn from New South Wales schools, researchers must take the following into account.
Approval of Schools Ethics Committees
(37) If the research is to be conducted in NSW, government schools or TAFE colleges, the approval of the NSW, Department of Education and Communities (DEC) is required. This may be sought while approval is being obtained from the University's Human Research Ethics Committee or other relevant delegated authority.
(38) For research involving independent schools, approval from the relevant administrative body is required.
Consent of Parents/Children
(39) In general, written parental consent being obtained for every school child who participates in research is required, regardless of the age of the child. This is in accord with NSW DEC requirements relating to research in NSW government schools. For independent schools, depending on the policy of the administrative body, an exception may be made in cases where the research is innocuous playground observation, or anonymous non-intrusive surveys. In these cases parents must still receive notification of the intended research with sufficient time to allow them to object to their child's inclusion. An approach which includes an opt-out consent mechanism will also be considered on a case-by-case basis. If there is any doubt about obtaining parental and/or child consent please contact the Human Ethics team (firstname.lastname@example.org).
(40) Where written consent is obtained it must be positive. That is, it is not acceptable to include children in the absence of a written non-consent being returned by parents. Furthermore, people should not be expected to identify themselves for the sole purpose of denying consent, i.e. they should only be asked to return a consent or participation form if they are consenting.
(41) Information statements must request parents to discuss the research invitation with their child and state that where parents’ consent to their child participating in a research project, the final decision will be the child's.
(42) Parents and students are to be assured in the information statement that participation or non-participation will not affect their school assessment.
Recruitment and Participation
(43) Recruitment and participation of school students must be conducted in a manner which does not make participants or non-participants conspicuous by their decision. For example, asking students who do not wish to participate to leave the classroom could cause them embarrassment. Where the research involves completion of questionnaires it would be preferable to request non-participating students to return a blank questionnaire at the same time completed questionnaires are returned. That way, only they will know if they are participating or not.
(44) Where it is necessary to group consenting students together, prior arrangements should be made with the school to provide alternative activities for those students for whom written parental consent is not received.
(45) If the research topic is of a sensitive nature, then it must be demonstrated that a protocol exists which identifies and caters for students who might be emotionally harmed by the research procedures, e.g. distressed, anxious etc, are in a situation which raises duty of care issues, e.g. child abuse, or who might be a danger to themselves or others, e.g. depressed or suicidal. Where the research topic is of a sensitive nature, or there is potential for harm, a suitable management strategy will need to be outlined in the application and reflected in the recruitment material.
Part E - Witness to a Participant's Signature
(46) Where participants are competent to sign for themselves, then it is not necessary to have their signature witnessed.
(47) However, this is not to say that participants' signatures cannot be witnessed. For example, if the investigator or a trial sponsor considered it important to have participants' signatures witnessed then there would usually be no objection to this being the case and a member of the research team could witness a participant's signature.
Part F - Recruitment of Participants in Public Spaces
(48) Where recruitment is undertaken in a public space, participants should be aware of the research prior to being approached. This could include the use of signage or other means of identifying the researchers and means to allow members of the public not to be included in an observation or other data collection process.
Part G - Reimbursement of Research Participants
(49) Reimbursement may be offered to potential research participants to cover the costs associated with participating in the research. Costs will usually include travel, parking and any accommodation or meals that may be required. Reimbursement may also be necessary to cover associated costs such as income forgone, childminding fees, or similar expenses.
Types of Reimbursement
(50) Reimbursement may be provided in the form of cash, or a cash refund, in kind (e.g. parking or shopping vouchers) or course credit. An alternative option is to recognise participants' willingness to participate by, for example, providing tickets in a prize draw.
(51) Other methods may be acceptable but all reimbursement options must comply with University policy and NSW law. Cash payments, for example, are subject to occupational health and safety guidelines (refer Section 3.1.9 Offsite Visit/Interview Safety Guidelines).
(52) If a prize draw method is used, it is considered a gratuitous lottery and must be conducted in accordance with the Lotteries and Art Unions Act 1901 and relevant state legislation. Please note that where a prize draw is the preferred means of reimbursement, researchers are encouraged to seek advice from the University's Legal Unit on the terms and conditions of the prize draw.
(53) If reimbursement is to be offered, participants must be advised of the type and amount of reimbursement and any conditions affecting when or how it will be paid. The type or amount of reimbursement may be indicated on advertising posters or handouts but full details must be provided on the participant information statement and given to potential participants in sufficient time to allow them to ask questions and to make informed decisions.It cannot be a condition of payment that a participant completes their involvement prior to reimbursement. Participants must be able to withdraw at any stage without financial penalty. Researchers may provide incremental payments as successive components or activities involving participants are completed.
(54) The level of any reimbursement offered must not induce or entice a person to take risks and must be commensurate with the activity. For example, reimbursement for a very brief commitment that involves little cost or inconvenience to participants is likely to be small compared to that for longer involvements that might cause the participant forgone income and marked inconvenience.
(55) The Human Research Ethics Committee or other relevant delegated authority are obliged to ensure that the level of reimbursement offered is commensurate with the activity and not an unreasonable inducement for a person to participate themselves or to involve those for whom they are legally responsible.
(56) Where the preferred reimbursement for participation is course credit, students should not be encouraged to accept a level of risk higher than would be considered acceptable where course credit was not available.
(57) If the amount of reimbursement proposed seems high to researchers it will usually also seem high human ethics reviewers and may be challenged. In that instance researchers are strongly advised to provide a brief justification in their application to facilitate human research ethics decision making.
(58) The amount of reimbursement will be considered in accordance with the National Statement on Ethical Conduct in Human Research which states: 'payment that is disproportionate to the time involved, or any other inducement that is likely to encourage participants to take risks, is ethically unacceptable' (NS 2.2.10).
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Section 4 - Roles and Responsibilities
(59) See Section 3 above. Depending on the research activity, the roles and responsibilities of researchers and research participants will differ.
(60) It is the role of the Human Research Ethics Committee or other relevant delegated authority to consider, approve and monitor research protocols including the recruitment of participants to ensure that research involving humans is being conducted in a safe and ethically responsible manner and in accordance with the requirements of the National Statement on Ethical Conduct in Human Research, as well as other relevant University policy and legislation.
(61) The Ethics Officer (Human) is responsible for receiving complaints from participants.