Conflict of Interest and Confidentiality Agreement for Peer Reviewers and Peer Review Observers
The Canadian Institutes of Health Research (CIHR) must meet the highest ethical and integrity standards in all that it does in order to continue to merit the trust and confidence of the research community, the government and the public. CIHR peer reviewers and observers must meet the highest standards of ethical behavior to maintain and enhance public confidence in CIHR’s ability to act in the public’s best interest and for the long-term public good. Where a conflict arises between private and public interests, peer reviewers and observers will be expected to take the necessary measures to ensure that the public interest is protected.
Conflict of Interest
A Conflict of Interest is a conflict between a person’s duties and responsibilities with regard to the review process, and that person’s private, professional, business or public interests. There may be a real, perceived or potential conflict of interest when the peer reviewer or observer:
- would receive professional or personal benefit resulting from the funding opportunity or application being reviewed;
- has a professional or personal relationship with an applicant or the applicant’s institution;
- has a direct or indirect financial interest in a funding opportunity or application being reviewed; or
- is currently under investigation for an alleged breach of Funding Organization policies.
A conflict of interest may be deemed to exist or perceived as such when peer reviewers or observers:
- are applicants within the competition and have ability to bias or influence the process to the benefit of their applicationFootnote 1.
- are a relative or close friend, or have a personal relationship with an applicant;
- are in a position to gain or lose financially/materially from the funding of an application;
- have had long-standing scientific or personal differences with an applicant;
- are currently affiliated with an applicant’s institution, organization or company—including research hospitals and research institutes;
- are closely professionally affiliated with an applicant, as a result of having in the last six years:
- frequent and regular interactions with an applicant in the course of their duties at their department, institution, organization or company;
- been a supervisor or a trainee of an applicant;
- collaborated, published or shared funding with an applicant, or have plans to do so in the immediate future; or
- been employed by the institution, when an institution is the applicant; and/or
- feel for any reason unable to provide an impartial review of the application.
Note: For trainee awards committees, these criteria also apply to the relationship with the proposed supervisor.
CIHR reserves the right to resolve areas of uncertainty and to determine if a conflict exists.
Disclosure and Compliance Measures
Any peer reviewer or observer who becomes aware of a conflict of interest must promptly disclose the conflict to CIHR staff. CIHR will determine if it constitutes a conflict of interest and what measures – such as recusal – are required. No peer reviewer or observer may participate in the review process of an application with which he/she is in conflict of interest. The conflict of interest depends on the role and level of involvement of a peer reviewer or observer and the size of the research team. Such disclosures and compliance measures shall be documented and retained for the record.
CIHR is subject to the Privacy Act, and the Access to Information Act. These laws govern the collection, use and disclosure of information under the control of the federal government and certain federally funded organizations. Documentation submitted to CIHR by the applicant may be provided to peer reviewers and observers. The documentation may contain personal information and confidential commercial information. By law, applicants have the right of access to the information provided by peer reviewers about their applications. The names of peer reviewers must be kept confidential during the review process to ensure they can provide an impartial review of an application. Peer reviewer names are made available 60 days after the publication of funding decisions; this process is solely at the discretion of CIHR. Written materials used in the review process are generally made available to applicants when they are notified of the funding opportunity results.
Peer reviewers and observers must ensure that:
- all documentation and information that CIHR entrusts to peer reviewers and observers is maintained in strict confidence at all times. It must be used only for the purpose for which it was originally collected – namely, to review applications and make funding recommendations as applicable;
- review documentation is stored in a secure manner to prevent unauthorized access. It must be transmitted using secure techniques and when it is no longer required, it must be destroyed in a secure manner. Any loss or theft of the documentation must be reported to CIHR; and
- all enquiries or representations received by peer reviewers or observers about an application or its review must be referred to CIHR. Peer reviewers or observers must not contact the applicants for additional information or disclose matters arising from the review process to the applicants.
Additional requirements for peer reviewers and observers:
- Review deliberations are confidential. Comments made during the review of an application and any related summaries or conclusions must never be discussed or disclosed with individuals not involved in the review process unless required by legislation or the courts.
- The identity of successful applicants and the details of the grants/awards must remain confidential until a decision is made by CIHR and officially announced to the applicants and the public. The identities of unsuccessful or ineligible applicants are not made public and must not be divulged unless required by legislation or the courts.
- During any meetings held, observers must be as unobtrusive as possible to minimize disruption and must not remove from the meeting room written notes or documentation related to reviewer assignments, ratings or reviewer comments on applications.
I have read and understood the Conflict of Interest and Confidentiality Agreement. I agree to comply with the requirements of the Conflict of Interest and Confidentiality Policy of the Federal Research Funding Organizations. (Additional information can be found in procedural guidelines for the specific review process.) I understand that any breach of this agreement will result in a review of the matter, with CIHR reserving the right to take appropriate action including, but not limited to, my removal from peer review service. The use of review documentation for any other purpose than intended could result in a CIHR investigation and/or report to the federal Privacy Commissioner’s Office. Any action that CIHR may or may not take will not prevent a person whose privacy rights have been compromised from seeking legal action against the respondent. By signing this form, I certify that I am not currently ineligible to apply for and/or hold funds from the Canada Foundation for Innovation (CFI), the Canadian Institutes of Health Research (CIHR), the Natural Sciences and Engineering Research Council of Canada (NSERC), the Social Sciences and Humanities Research Council of Canada (SSHRC) or any other research or research funding organization worldwide for reasons of breach of policies on responsible conduct of research – such as ethics, integrity or financial management policies. Similarly, I also certify that I am not currently under investigation for a breach of such policies. If I become the subject of such an investigation, I will immediately withdraw from participation in the CIHR review process(es) until the investigation is complete and CIHR has determined that I am once again eligible to participate.
I agree to take personal responsibility for complying with these requirements.
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