Procedure for Addressing Potential Breaches of Research Integrity

1.1. This Procedure sets out how the University of Oxford (‘the University’) receives, assesses and investigates concerns relating to potential breaches of research integrity. It is designed to ensure that such concerns are handled in a manner that is fair, transparent, timely, and proportionate, in alignment with the requirements of the Concordat to Support Research Integrity 2025 (‘the Concordat’), guidance from the UK Research Integrity Office (UKRIO) and the conditions of funders and regulators. The Procedure exists in parallel with the University Research Integrity Policy (‘the Policy’), which sets out the expectations of the University in relation to research practice and conduct. For operational clarity, a summary of actions or omissions that constitute a breach of research integrity is provided at 1.3 below, with full definitions set out in the Policy (section 4).  

1.2. Through use of this Procedure, the University is committed to ensuring that concerns around potential breaches of research integrity are investigated in a manner that is fair, transparent and proportionate, and undertaken with appropriate rigour, and that all investigations are underpinned by the principles of Fairness, Confidentiality, Integrity, Prevention of Detriment, and Balance¹.  

1.3. This Procedure applies where there is a concern around a breach or breaches of research integrity as defined in the Policy². For the purposes of this Procedure, a breach of research integrity has the meaning given in 4.1 of the Policy: it occurs where an action or omission of the kind described in 4.2 of the Policy is carried out intentionally, recklessly or negligently, such that the principles and expectations set out in the Policy are not upheld. The University recognises that some concerns may relate to Questionable Research Practices (QRPs); QRPs do not necessarily constitute breaches of research integrity unless they amount to reckless or negligent departures from accepted standards (see Policy 4.3). In addition, the University may resolve concerns relating to honest minor error, legitimate differences in interpretation and minor lapses in good practice arising from lack of experience or knowledge through mediation, training, supervision or mentoring, rather than treating them as breaches of research integrity or pursuing formal investigation under this Procedure. For the avoidance of doubt, breaches include fabrication, falsification, plagiarism, misrepresentation, misuse of others’ work, failure to meet legal/ethical requirements, inappropriate authorship practices, failure to declare or manage conflicts of interest, improper conduct during peer review, collusion or concealment of breaches, and improper handling of concerns (defined in full in the Policy, section 4). 

1.4. This Procedure does not apply where concerns relate to bullying, harassment, or other forms of misconduct which should be raised via the University disciplinary procedures; such concerns will be redirected to the appropriate process if received under this Procedure.  

1.5. The Named Person at the University responsible for dealing with potential breaches of research integrity is the Registrar, supported by others as detailed in Annexe A – Roles and Responsibilities. 

2.1. Concerns received by the University relating to breaches of research integrity will be handled in a proportionate and fair manner. Where appropriate, the University may employ informal routes to resolution, including addressing the matter within the relevant Department or Faculty (hereafter referred to as ‘Department’), providing appropriate steps are taken to ensure independence and to avoid potential conflicts of interest.

2.2. The University will take steps to ensure that conflicts of interest (including conflicts which are actual, potential or perceived) are avoided or appropriately managed at every stage of this Procedure, applying to all parties involved including decision-makers, panel members and investigators. All individuals involved in decision-making at any stage must declare any actual, potential or perceived conflicts of interest in writing; such declarations will be retained as part of the case record. 

2.3. Concerns that fall within the scope of this Procedure may also engage other University policies, regulatory requirements, or statutory obligations. This includes (but is not limited to) areas such as Trusted Research and export control, clinical research governance, fitness to practice, data protection, freedom of speech and health and safety. Investigations into legislative or compliance breaches will be undertaken through separate procedures and will take precedence over or be undertaken in parallel with this Procedure, led by the relevant specialist team (e.g. Research Governance, Ethics and Assurance team (RGEA), Trusted Research team). Where a concern intersects with additional compliance requirements or procedures, the University will determine the appropriate sequencing and coordination of processes to ensure legal and regulatory obligations are met, ensuring relevant teams are consulted and clear communication is provided to the parties. Progression of this Procedure may be paused by the Registrar where compliance or legislative investigations are running in parallel and such investigations must take precedence.

2.4. Where a concern indicates, or may indicate, potential noncompliance with export controls, sanctions, or Trusted Research requirements, the relevant aspect of the matter must be managed in accordance with the University’s Managing Suspected or Actual Non-Compliance with Export Control Regulations and Sanctions Standard Operating Procedure (SOP) and any associated Trusted Research processes. The SOP sets out the University’s formal investigative framework for such issues, including triage, containment, evidential standards, voluntary disclosure processes, escalation and regulatory engagement. Any consideration of research integrity issues under this Procedure will proceed only where this does not prejudice, duplicate or conflict with the SOP process.

2.5. Where a concern requires notification to legal or regulatory authorities (for example, where the alleged activity may constitute a criminal offence), the Registrar will consider whether to suspend further action under this Procedure and/or may declare further action under this Procedure unnecessary. 

2.6. The University may decline to investigate or discontinue investigation of concerns that are considered to be vexatious, frivolous, malicious or otherwise an abuse of process. Where such concerns are identified, the University may consider taking appropriate action against the Initiator.

2.7. The University will follow this Procedure through to its natural end point as far as possible, including in the event that:

• Any individual(s) concerned leaves or has left the jurisdiction of the University, either before the operation of this Procedure is concluded or before the concern was raised; or  
• The individual raising the concern (hereafter referred to as the ‘Initiator’) withdraws the concern raised at any stage; or
• The individual(s) about whom the concern was raised (hereafter referred to as the ‘Respondent’) admits the alleged breach in full or in part; or  
• The Respondent(s) admits other forms of misconduct, whether research or otherwise; and/or  
• The Initiator(s) and/or the Respondent(s) withdraws from the Procedure.  

2.8. In cases where a concern involves research conducted in collaboration with external organisations, the University will work with those organisations to coordinate aspects of the investigation, determine responsibilities and ensure a consistent approach. This will be done in line with relevant partnership agreements and sector guidance including the Russell Group Statement of Cooperation in Respect of Cross-Institutional Research Misconduct Concerns.  

2.9. Where counter-concerns or complaints are raised during the course of an investigation, or where evidence of additional potential breaches of research integrity come to light, these will normally be recorded and considered under the appropriate University procedure as distinct from and without detriment to the progression of the original investigation.   

2.10. Where a concern relates to historic events or activities, the Registrar reserves the right to decline to consider concerns where the substantive event(s) occurred more than ten years prior to the concern being raised. Concerns should be raised at the earliest reasonable opportunity, as the University may be unable to locate or verify evidence, records or witness accounts relating to older events. While reasonable efforts will be made to gather available information, the passage of time may prevent the University from investigating a concern fairly, proportionately and to the standard required under this Procedure.   

2.11. The Registrar (and the Pro-Vice Chancellor for the purposes of appeal) reserves the discretion to extend any procedural time limit (as set out below) where necessary to ensure a fair, thorough and proportionate investigation. Where practicable, any extensions to time limits will be communicated to the parties involved to ensure transparency.  

2.12. The Registrar and the members of any convened Panel will be assisted throughout this Procedure by the Case Manager, Academic Advisor(s) (where relevant) and the Research Integrity Advisory Group (RIAG) (see Annexe A – Roles and Responsibilities).   

2.13. The standard of proof to be applied throughout application of this Procedure is ‘on the balance of probabilities’. The burden of proof rests with the University, not the Respondent; however, in certain circumstances there may be a burden on the Respondent to provide evidence to support a contention, or for example in support of mitigating factors they rely upon.  

2.14. Decisions made at each stage of this Procedure are final and will not be reconsidered unless an appeal is lodged which meets the required threshold (see section 9 below).

3.1. The University will ensure that all parties involved in this Procedure (including witnesses and individuals providing evidence) will have access to appropriate support, including accessibility/disability adjustments, and access to independent advice³ and wellbeing support where practicable. The Case Manager will make required arrangements to facilitate any adjustments, signpost to appropriate sources of advice and support, and ensure the fair and effective participation of all parties.  

3.2. Any individual providing evidence via a meeting or interview has the right to be accompanied. Staff may be accompanied by a Trade Union representative or University employee of their choice, and students may be accompanied by a fellow student, a member of staff from Oxford Student’s Union Advice Service, or a member of staff of their choice.  

3.3. The University will provide clear and timely communication to all parties throughout the Procedure to support their understanding of the process and ensure effective participation.

4.1. All parties to an investigation including witnesses, representatives and individuals providing information or expert advice have a duty to maintain confidentiality. Evidence may be shared among members of staff responsible for managing and supporting an investigation. Access to evidence and information will be restricted to those with a legitimate need to know for the purposes of ensuring rigorous and proportionate assessment of the case and any associated potential legislative or compliance breach, and all parties will act in accordance with relevant data protection legislation and the University’s legal obligations. All evidence will be stored securely with restricted access and a full audit trail.  

4.2. Records relating to concerns and any subsequent investigation carried out under this Procedure will be retained for a minimum of ten years (or longer where required by funders, regulators or legal obligations) in accordance with University retention schedules, after which period anonymised summary information relating to investigations will be retained. 

4.3. In line with the University’s obligations under the Concordat and its commitment to transparency in its research integrity processes, an annual anonymised summary statement including statistical information will be published relating to cases considered under this Procedure. Such reporting will not contain information which could reasonably identify any individual. Where appropriate, the University will share learning from anonymised cases to support continuous improvement across the research community. 

4.4. Where an Initiator wishes to remain anonymous, the Registrar will consider the seriousness of the issues raised and the feasibility of gathering sufficient, verifiable information from other credible sources. The Registrar may elect to investigate anonymous allegations under this Procedure only if it is considered feasible to do so. 

4.5. The University will maintain confidentiality (and where requested, anonymity) as far as reasonably possible, within the limits of legal or regulatory compliance including safeguarding considerations.

5.1. All members of the University have a responsibility to raise concerns about potential breaches of research integrity, whether arising from direct observation or from indications that the integrity of the research may be affected, in order to ensure that issues are identified promptly, addressed fairly, and do not compromise the quality or ethical standards of the University’s research. Concerns may be raised by staff, students, visiting researchers, collaborators, or external individuals or organisations. The University will treat all concerns sensitively, fairly, and proportionately, and will ensure that individuals who raise concerns are supported throughout the process where practicable. Retaliation against individuals who raise concerns in good faith is prohibited and will be treated as a serious matter in its own right. 

5.2. Seeking Advice The University promotes an open culture which supports confidential discussion of concerns at the earliest opportunity. Individuals who are concerned about conduct or thinking of raising a concern may first wish to seek advice from the following sources: 

• Supervisors and mentors  
• Directors of Graduate Studies
• Heads of Department, Faculty or Division
• University Proctors ([email protected])  
• Research Services (contact Kate Dunbar, Research Policy Manager (Integrity) in the first instance: [email protected])  
• Oxford University Students Union  

5.3. Raising a concern informally Concerns may be raised informally (by the Initiator or by those listed in 5.2 above who have been contacted) through discussion in confidence with the nominated person in Research Services (Kate Dunbar, Research Policy Manager (Integrity) – [email protected]). For the avoidance of doubt, seeking informal discussion is not a required stage of the process and a formal concern may be raised under section 5.4. below without first having an informal discussion. Concerns raised informally may be directed to formal procedures as set out below if deemed appropriate. 

5.4. Raising a concern formally Concerns raised formally must be presented in writing and accompanied by supporting evidence to [email protected] (via email) or addressed to The Registrar, University of Oxford, University Offices, Wellington Square, Oxford OX1 2JD (via post).  

5.5. When raising a concern, the Initiator should provide as much relevant information as possible in order to ensure a fair and proportionate assessment. This will normally include a clear description of the concern and the specific actions or omissions alleged, the identities of those involved, the dates or timeframe of the events, any supporting evidence documents, data, correspondence or witness accounts, and details of any steps already taken to address or discuss the matter (e.g. with the Department). The University recognises that Initiators may not always have access to complete information, and concerns will be assessed on the basis of the evidence which can be reasonably obtained. 

5.6. Other support Individuals who find their research to be the subject of a concern, or who believe a breach may have occurred which impacts on their research, should seek advice via the above routes in the first instance, so that the University can support them through the process and ensure correct application of this Procedure.

6.1. Where appropriate, the University may seek to resolve concerns informally where they relate to minor lapses, errors or QRPs that do not meet the threshold for a breach of research integrity. Informal resolution measures will normally be facilitated by the relevant academic Department upon referral by the Registrar. This may occur following stages 2 or 3 of this Procedure (see section 7 below) or following an appeal (see section 9 below). Specific measures may include (but are not limited to): 

• Facilitated or mediated discussion
• Education, mentoring or training, or other development activities
• Enhanced supervision or oversight of research activities
• Restriction of research activities
• Revision of relevant research practices, systems and/or policies relating to the concern
• Other proportionate measures as deemed appropriate to the nature of the concern.  Informal measures will not be used where the concern, if substantiated, may meet the threshold for a breach of research integrity as defined in the Policy (section 4).   

6.2. Concerns relating to authorship or attribution disputes that do not involve evidence of a serious breach as defined in the Policy will normally be resolved at Departmental level. Where such concerns are raised under this Procedure, the Registrar may refer them back to the Head of Department (or equivalent, see 6.3 below) for local informal resolution.  

6.3. Where concerns are referred to the Department for informal resolution, these will be referred to the Head of Department unless there is a potential conflict of interest, in which case an alternative Head of Department or the Head of Division or equivalent will be asked to step in. Heads of Department receiving concerns independently are required to notify Research Services (by email to Kate Dunbar, Research Policy Manager (Integrity) – [email protected]) to ensure correct application of this Procedure and to determine whether a legislative or compliance breach may require additional action or investigation, which will be led by the relevant team. 

6.4. Where a concern is resolved using informal measures, the following features of an effective system of resolution should be used: 

• The nature and scope of the informal measures should be clearly defined
• A designated person, working with the Case Manager and others as necessary, should be responsible for ensuring that the agreed measures are implemented
• Their duration should be clearly set out
• Appropriate documentation should record the implementation and outcomes of the informal measures, and any next steps
• Once completed, there should be a discussion conducted by the Research Policy Manager (Integrity) and others about any learning points for the University.  

6.5. The use of informal resolution measures will not prevent further formal investigation commencing or resuming if new information comes to light or if the Registrar considers that the informal resolution measures are not effective or sufficient to address the concern.  

7.1. The timescales set out in this section are indicative and represent the University’s normal expectations for progressing a concern. While every effort will be made to meet them, the Registrar may extend any timeframe where necessary to ensure a fair, thorough and proportionate investigation, including where the complexity of a case or external regulatory requirements make this unavoidable. 

7.2. Throughout stages 1 and 2 of this Procedure, the Registrar will be supported in making decisions by the Case Manager and the RIAG, and may appoint an Academic Advisor and/or seek expert advice as needed.  Stage 1: Receipt and triage of a concern 7

.3. Within five working days of receipt of a concern, the Registrar will acknowledge it and provide an outline of the next steps to the Initiator. Details of the concern will be recorded. The Registrar will identify whether any immediate action is required to prevent harm, illegal activity or to mitigate risk, such as temporary measures to protect research participants, staff or students (any such measures are precautionary and do not imply any judgement about the validity of the concern). Any urgent regulatory reporting requirements will be identified at this early stage by notification of the concern to the RIAG, which will support decision-making at this and any subsequent stages of the Procedure. 

7.4. Within ten working days of receipt of the concern, the Registrar (supported by the RIAG and other relevant expertise) will conduct a triage assessment to determine whether the concern falls within scope of this Procedure or should be directed to another University process (e.g. staff disciplinary procedures or student conduct procedures). If the concern is in scope, the Registrar will consider whether the concern raised contains enough information to proceed (and to gather additional information from the Initiator if needed), and identify any requirement to notify external parties (such as funders or collaborators) and relevant internal parties including the Central University Research Ethics Committee (CUREC) for research approved by one of CUREC’s sub-committees. The Respondent of the concern will normally be notified at this stage and instructed on their duty to cooperate with any subsequent investigation, to maintain confidentiality and to retain all data and records pertaining to the concern.  

7.5. The possible outcomes at stage 1 are: 

a) concern is potentially in scope of this Procedure and contains sufficient information to be substantiated through further assessment – proceed to stage 2 

b) concern is potentially within scope of another formal procedure (e.g. financial misconduct, bullying & harassment) – refer internally 

c) concern is outside scope of University procedures but requires referral externally (e.g. statutory regulators, professional bodies) – refer externally 

d) concern does not fall within scope of this or any other formal procedure – dismiss concern  

e) concern is not substantiated due to insufficient information or evidence to allow further assessment – dismiss concern 

f) concern is not substantiated and is identified as mistaken/unfounded/otherwise without substance – dismiss concern 

g) concern is not substantiated and is identified as vexatious/malicious – dismiss concern 

For the avoidance of doubt, no determination is made at Stage 1 as to whether a breach of research integrity has occurred.  

Stage 2: Initial investigation  

7.6. Within (normally) 30 working days of receipt of the concern, the Case Manager (reporting to the Registrar and supported by the RIAG and other relevant expertise) will undertake a proportionate, structured fact-finding exercise to determine whether there is a case to answer and whether formal investigation is warranted. This may include gathering and reviewing evidence, seeking clarification from the Respondent where appropriate, and consulting experts as needed (including by appointment of an Academic Advisor(s) to provide relevant information to the Registrar on specialist elements). The Case Manager will make recommendations in the form of a written summary to the Registrar at this stage to consider whether the concern may be resolved proportionately through informal measures as set out at 6.1 above, or whether the concern has sufficient substance, seriousness, and evidential basis to proceed to stage 3 below.  

7.7. A summary of the findings may be shared with the Respondent where appropriate; comments will only be invited where necessary to ensure fairness or to clarify material points.  

7.8. The written summary will be provided to the Registrar to support a decision on next steps, and will include:  

• Details of the concern
• Evidence reviewed
• The Respondent’s written response (if sought)
• Any expert input
• The Case Manager’s recommendation and reasoning   

7.9. Where the concern is to proceed to a formal investigation under stage 3 (below), the Registrar will determine whether any funder, regulator or external body must be notified at this point in accordance with contractual or regulatory requirements. 

7.10. The possible outcomes at stage 2 are: 

a) concern is substantiated and may meet the threshold for a breach of research integrity - proceed to stage 3 

b) concern is substantiated but does not meet the threshold for a breach of research integrity – refer to the relevant academic Department for resolution using informal measures (see 6.1. above) 

c) concern is substantiated in relation to legislative or compliance requirements but does not meet the threshold for a breach of research integrity – refer the compliance aspect to relevant specialist team, and academic conduct issues to the relevant academic Department for resolution using informal measures  

d) concern relates to matters that fall within scope of another formal procedure (e.g. financial misconduct, bullying & harassment) – refer internally 

e) concern is outside scope of University procedures but requires referral externally (e.g. statutory regulators, professional bodies) – refer externally 

f) concern does not fall within scope of this or any other formal procedure – dismiss concern  

g) concern is not substantiated due to insufficient information or evidence to allow further assessment – dismiss concern 

h) concern is not substantiated (mistaken/frivolous/otherwise without substance) – dismiss concern

i) concern is not substantiated (vexatious/malicious) – dismiss concern 

Stage 3: Full investigation 7

7.11. The Registrar will convene an Investigation Panel (see Annexe A) to review all evidence collated and findings made during stages 1 and 2, to carry out any further investigation as needed and to provide a report and recommendations based on its findings. Subject to operational demands, the Panel will normally convene, conduct its investigation and report its findings within 90 working days from receipt of the concern by the Registrar.  

7.12. The Panel shall normally be comprised of three members, to include: 

• *One member of the University with relevant subject expertise who is normally external to the Respondent’s Department (where practicable, to be replaced by a member within the Respondent’s Department where conflict of interest can be avoided),
• One member of the University (or a College) with relevant institutional or methodological expertise who is external to the Respondent’s Department, and  
• One member who must be external to the University⁴. 

Panels will be formed to reflect the range of expertise particular to the case, and the membership may be supplemented with additional specialists where required (this also applies to the composition of an Appeals Panel, see 9.5 below). 

7.13. The Registrar will provide the Panel with clear terms of reference, outlining the scope of the investigation and the questions to be addressed. Members will be provided with the following information: 

• A copy of this Procedure
• Details of the concern(s) to be considered
• A summary of correspondence with the Initiator and Respondent(s) to date
• Copies of all information and evidence gathered during stages 1 and 2 (including any investigation by a specialist team e.g. RGEA, Trusted Research team). 

7.14. Where funders or regulators have been notified of the formal investigation, the Panel will be informed by the Registrar of any reporting requirements or timelines specified by those bodies to ensure compliance with external obligations. 

7.15. The Panel will be charged with examining and evaluating the facts relating to the concern along with all relevant evidence in order to determine whether a breach (or breaches) of research integrity have occurred, who is responsible and the seriousness of the breach, in order to report to the Registrar. The Panel will operate in accordance with the principles of natural justice, ensuring fairness, impartiality, and the right of the Respondent to respond to relevant evidence. 

7.16. The Panel will normally interview both the Initiator and the Respondent, and any other individual(s) whose evidence may assist the Panel in reaching its conclusions. The Respondent will have the right to respond to the issues raised, set out their case and submit any evidence to the Panel for consideration before an interview takes place. If either the Respondent or the Initiator does not wish to be interviewed, steps should be taken to assist their engagement with the process by other means such as permitting written responses by email. The Panel should be informed in writing of the identities of any accompanying persons (see 3.2 above) at least 5 working days before an interview takes place. The Panel may also seek advice from relevant experts as required. 

7.17. The Panel will maintain a clear record of all evidence reviewed, interviews conducted (if any) and decisions made.  

7.18. The Panel shall prepare a report setting out its findings of fact, its conclusions as to whether the concern should be upheld in full, in part or dismissed, and its recommendations to the Registrar regarding seriousness and any actions that may be appropriate. The Respondent will be provided with all evidence considered by the Panel, except where redaction is required for legal or safeguarding reasons.  

7.19. The Panel shall provide the draft report to the Respondent and the Initiator for their comments on its factual accuracy, normally allowing up to 10 working days to provide comments in writing. The Panel will then consider any comments on the draft report and provide a final version to the Registrar, who will determine what further steps will be taken. If any comments made by the Respondent or the Initiator are not accepted by the Panel, they shall also be provided to the Registrar to be taken into account.  

7.20. Should any evidence of further, distinct instances of a breach in research integrity come to light during the course of the Panel investigation (either unconnected to the present concern or involving another person or persons), the Panel will submit these new concerns in writing to the Registrar in accordance with section 5 above.  

7.21. Based on the Panel’s findings and recommendations, the Registrar will determine whether a breach of research integrity has occurred. The possible determinations at stage 3 are: 

a) finding of a breach of research integrity is upheld 

b) finding of a breach of research integrity is upheld in part (i.e. at least one, but not all, alleged breaches have been found) 

c) concern is substantiated but does not meet the threshold for a breach of research integrity – refer to the relevant academic Department for resolution using informal measures (see 6.1. above) 

d) concern has some substance in relation to legislative or compliance requirements but arises from misunderstanding or lack of knowledge not considered negligent – refer the compliance aspect to relevant specialist team, and academic conduct issues to the relevant academic Department for resolution using informal measures 

e) concern relates to matters that fall within scope of another formal procedure (e.g. financial misconduct, bullying & harassment) – refer internally 

f) concern is outside scope of University procedures but requires referral externally (e.g. statutory regulators, professional bodies) 

g) concern does not fall within scope of this or any other formal procedure – dismiss concern  

h)  concern is not substantiated due to insufficient information or evidence to allow further assessment – dismiss concern 

i) concern is not substantiated (mistaken/frivolous/otherwise without substance) – dismiss concern 

j) concern is not substantiated (vexatious/malicious) – dismiss concern

8.1. Outcomes and actions may arise at any stage of this Procedure, including following informal resolution or completion of an initial or formal investigation. The Registrar will determine the appropriate outcome and any actions required, taking into account the information available and any recommendations made at the relevant stage. Possible outcomes include a finding that no breach has occurred, that the concern is substantiated but does not meet the threshold for a breach and can therefore be addressed through informal measures such as training or supervision, or that a breach has occurred requiring action through disciplinary procedures and/or reporting to external regulatory bodies. In determining seriousness, the Registrar will have regard to the definitions of breach and serious breach set out in the Policy (section 4), and consider any legal, ethical or regulatory obligations engaged (see 2.3 above). A breach that is minor in academic or research-practice terms may still constitute a significant breach of legislation, regulation or funder requirements (e.g. in areas such as Trusted Research, data protection or export control) and may therefore require formal action, external reporting or other proportionate measures. 

8.2. Where a stage 3 Panel has been convened, the Registrar will determine the appropriate outcome and any actions required, taking into account the recommendations made in the Panel’s report. The Registrar will provide the Respondent and the Initiator with a written determination normally within 15 working days of receipt of the Panel’s report, summarising the decision and the reasons upon which it is based. 

8.3. Following the conclusion of any stage of this Procedure, the Registrar may identify actions to improve systems, processes, or training within the University. The Registrar will communicate the outcome to the parties involved and will ensure that any actions are recorded and implemented in a timely manner. Where required by funders, regulators or contractual obligations, the University will notify relevant external bodies at the start of a formal investigation and upon its conclusion, or may notify such bodies where necessary to meet its obligations.

8.4. The following University actions may be undertaken following conclusion of an investigation: 

a) appropriate transfer of information to other University teams and procedures (including Statute XII Part D for staff subject to its provisions or Statute XI for students subject to its provisions) and for use of informal measures by referral to the relevant Department 

b) reporting of outcome to relevant Head of Department where the concern relates to an individual subject to the provisions of the University disciplinary procedure for support staff 

c) reporting of outcome to other internal teams (e.g. relevant academic Departments, Divisions or Faculties) and to relevant Committees 

d) reporting of outcome to external organisations and interested parties (including funders, publishers, ethics committees, co-authors, collaborators, regulators, professional bodies as they relate to Fitness to Practice, employers of Respondents not employed by the University) 

e) actions around duty of care to Initiators, Respondents and other involved parties such as research participants (or their guardians), patients or clinical teams (this may include safeguarding measures or adjustments as well as notification of the outcome) 

f) ensuring appropriate action is taken to correct the record of research 

g) withdrawal/repayment of funding 

h) recording of the outcome on relevant employment records 

i) revocation of any degrees awarded based on research subject to a concern upheld in full or in part (subject to determination by Council) 

j) addressing procedural or institutional issues identified during the investigation and ensuring appropriate action on systemic improvements 

k) initiating proceedings in respect of any further potential instances of a breach uncovered during the investigation 

l) ensuring communication of anonymised summary data for inclusion in the annual statement. The above actions should take into account any recommendations made by the Panel at the conclusion of stage 3 (where relevant) and any need to involve internal or external stakeholders relevant to the action. 

8.5. Where a concern is referred to the relevant academic Department for resolution through informal measures, the University will record the outcome and any agreed actions, with appropriate time limits for completion. The Department will be required to report on progress against these actions for the University record to be updated, and to underpin any decision to resume or commence a formal investigation. 

8.6. Where a concern is upheld in full or in part, the Registrar will implement remedial actions to correct the record of research, and record any agreed actions such as requirements for training or enhanced supervision, revisions to University processes or governance arrangements, or referral to staff or student disciplinary processes as appropriate. The Registrar will consider any wider implications of the breach and implement measures to prevent recurrence and support best practice in research.  

8.7. Where a concern is upheld in full or in part relating to a significant body of work over a significant period of time, the Registrar may consider reviewing other work carried out by the Respondent(s), including work not specifically identified as being of concern in the course of the investigation. 

8.8. Where a concern is dismissed because it is unfounded, mistaken, frivolous or otherwise without substance, the Registrar may undertake the following actions: 

• appropriate steps to preserve the good reputation of the Respondent, such as release of an official statement if the matter has received any adverse publicity
• appropriate steps to preserve the good reputation of the Initiator where concerns have been raised in good faith
• referral to relevant support and wellbeing services for the Respondent and if needed, the Initiator (where practicable)
• appropriate communications on the outcome and its basis to ensure transparency and continuous improvement of practice. 

8.9. Where a concern has been found to be vexatious or malicious in nature, the University may take appropriate action against the Initiator under the relevant staff or student disciplinary procedures and may implement measures to prevent future misuse of this Procedure. The University may also implement actions as set out in 8.8. above. 

8.10. Once a concern has been addressed to its natural end point and to the University’s satisfaction, the Registrar (supported by the Case Manager) will carry out a formal review and closure process to ensure the concern has been dealt with, recorded and reported appropriately. This will include formal sign-off by the Registrar, formal notification of outcome to any interested parties and recording of the outcome in accordance with University-wide data retention policies for staff and student data. 
 

9.1. The University provides a limited right of appeal to ensure that decisions made under this Procedure are fair and reasonable. An appeal is not a rehearing of the case and will only be considered on specific grounds.  

9.2. A Respondent may submit an appeal to the Pro-Vice-Chancellor (Research) (PVC-R) within 10 working days of receiving the written outcome of stage 3 of this Procedure. Appeals will only be accepted on one or more of the following grounds: a) Procedural irregularity in the conduct of this Procedure that affected the outcome b) Fresh evidence becoming available which was not, and could not, have been made available earlier and which may have affected the outcome c) The decision reached was manifestly unreasonable in light of the evidence available. For the avoidance of doubt, appeals are only permitted by a Respondent in relation to a stage 3 outcome and by no other person(s) or in relation to any other stage. 

9.3. Upon receipt of an appeal, the PVC-R will nominate a Pro-Vice-Chancellor with portfolio (nominated PVC), having regard to availability and any potential conflicts of interest, to determine whether the appeal meets the threshold for consideration and to oversee the appeal. The nominated PVC may seek advice or further information from any relevant person, including members of the original Panel. If it is considered that the appeal does not fall within one or more of the criteria set out at 9.2 above, the appeal will be dismissed and the decision communicated to the person seeking the appeal. If the appeal does meet the threshold, an Appeals Panel will be convened comprised as follows: 

• At least one member who must be external to the University
• One member of the University with subject expertise relevant to the concern
• One member of the University (or a College) with relevant institutional or methodological expertise who is external to the Respondent’s Department  
• All members of the Appeals Panel will be independent of, and will not have participated in, any prior stage of consideration of the concern under this Procedure. 

The nominated PVC will appoint one member of the Appeal Panel to act as Chair. Panels will be formed to reflect the range of expertise particular to the case, and the membership may be supplemented with additional specialists where required.  

9.4. Any appeal should normally be heard within two months of the outcome of the investigation.  

9.5. The Appeals Panel will produce a report setting out its findings and recommendations, recording any differing views. The Appeals Panel may make recommendations alongside its decision to improve procedural practice, even where the original outcome remains unchanged. A summary of the conclusions will be sent to the Initiator and the Respondent to check factual accuracy, with up to 10 working days to provide comment, after which the Appeals Panel will consider the responses received and whether any errors of fact require amendment within the report. The Appeals Panel will submit their report to the nominated PVC along with all records and evidence relating to the Full Investigation.  

9.6.  Upon receipt of the Appeals Panel report, the nominated PVC will decide whether to uphold (in full or in part) or dismiss the appeal. The nominated PVC will write to the Initiator and the Respondent to set out the findings and recommendations of the Appeals Panel and inform them of the final decision. 

9.7. The nominated PVC will undertake any necessary actions to implement the findings and recommendations of the Appeals Panel in line with 8.4. above.  The possible outcomes of the appeal stage are: 

a) The appeal is dismissed (original findings and outcomes are upheld) 

b) The appeal is upheld in full (original findings and/or outcomes are set aside) 

c) The appeal is upheld in part (specific outcomes or findings are amended). 

9.8. Where disclosures to external bodies have already been made on the basis of the original investigation, the Registrar will determine whether any clarification, correction or update is required and will communicate such information to those bodies in a timely manner. 

9.9. The decision of the nominated PVC is final and constitutes the final stage of the University’s internal procedures.

10.1. In relation to students, the University will issue a Completion of Procedures letter (CoP) only once this Procedure has been fully concluded, normally following the outcome of any appeal. Where a concern is resolved at an earlier stage, such as through informal resolution, the Procedure will be considered complete at that point, and the parties will be notified of the outcome and any actions arising. Research Services (RSPU) will retain a record of all cases resolved before stage 3, including the nature of the concern, the stage at which it concluded and any actions taken, to support institutional learning and assurance reporting and in accordance with 4.2 above.  

10.2. Following the issuance of a CoP, students may submit a complaint to the Office of the Independent Adjudicator for Higher Education (OIA) for review if they remain dissatisfied following completion of this Procedure. This must be submitted within 12 months of the date of the CoP. 

• Quick Guide to the Research Integrity Procedure (SSO)
• Research Integrity Procedure Guidance for Initiators (SSO)
• Research Integrity Procedure Guidance for Respondents (SSO)
• Research Integrity Procedure Role Guide: Case Manager (SSO)
• Research Integrity Procedure Role Guide: RIAG Members (SSO)
• Research Integrity Procedure Role Guide: Academic Advisors (SSO)
• Research Integrity Procedure Role Guide: Heads of Department/Faculty (SSO)
• Research Integrity Procedure Role Guide: Panel Members (SSO)

UK Research Integrity Office

Roles and Responsibilities 

The below sets out the roles and responsibilities for reporting, managing, investigating and recording potential breaches of research integrity at the University of Oxford. All parties are expected to work together collaboratively to ensure timely progression of the Procedure. Individuals are required to cooperate with an investigation and to provide relevant evidence promptly where requested. 

Initiator: the individual raising a concern or concerns about a potential breach of research integrity. They need not be a member of the University. 

Respondent: the individual responsible for the research in question. 

Registrar: the named senior person at the University responsible for dealing with potential breaches of research integrity. In practice, this may include the Deputy Registrar or another person duly authorised to represent the Registrar on their behalf such as a nominated investigator (referred to throughout this Procedure as ‘the Registrar’).  

Case Manager: the member(s) of staff responsible for case handling, coordination of investigations, communication with parties and liaising with Departments or Faculties on behalf of the Registrar. Case handling may include assessment of a concern and determining appropriate proportionate action, with or on behalf of the Registrar in undertaking administrative or procedural functions to support the operation of this Procedure (excluding substantive decisions relating to the outcome of a concern). 

Research Integrity Advisory Group (RIAG): a small advisory group of University staff representing relevant specialisms including Legal Services, the People Department, the Proctors’ Office, the Research Governance, Ethics and Assurance (RGEA) team, the Compliance team, the Trusted Research team, research practice and integrity experts. This Group will be engaged at the earliest opportunity to aid in the assessment of the correct University procedure to handle a particular concern and advise on sequencing and coordination of processes to ensure legal and regulatory obligations are met. 

Academic Advisor: a member of academic staff engaged to provide expert advice to the Registrar on a particular research field or specialism as it relates to a concern. 

Investigation Panel: Panel convened by the Registrar comprised of (normally) three members as detailed at 7.12. Members of the Panel must have no conflicts of interest in the case, and they must have appropriate knowledge and experience to assess the issues under investigation. The Panel is charged with evaluating the facts and all available evidence relevant to the potential breach to determine whether the concern is upheld (in full or in part) or dismissed. The Investigation Panel may reach its conclusions by consensus. 

Appeals Panel: Panel convened by the nominated Pro-Vice-Chancellor and comprised of at least three members as detailed at 9.3. Members of the Appeals Panel must have no conflicts of interest nor any prior involvement with the case, and they must have appropriate knowledge and experience to assess the issues under investigation. The Appeals Panel is charged with deciding whether it upholds, reverses or modifies decision(s) and/or recommendations made previously under the Procedure.