This policy sets out our position and commitment to fostering a culture in research where everyone is treated with dignity and respect. We believe that all people working at our organisation or involved in our funded activities should be able to work in an environment where everyone is treated, and treats others, fairly and with respect. Behaviour that causes harm of any kind is unacceptable and is not tolerated.
This policy applies to all participants involved in our research as outlined in our policy. Our policy for Research Involving Human Participants covers our position on all research involving human participants, including clinical trials, behavioural intervention trials and clinical studies. Our commitment to our staff and volunteers is addressed separately in our dignity at work and safeguarding policies. This document deals specifically with those involved in research activities that we fund and support.
We define behaviours that cause abuse and harm, bullying and harassment as outlined in this section, however, institutions should follow their own institutional policy definitions.
Bullying | Bullying can be, but is not limited to, abusive, offensive, malicious, insulting, intimidating or manipulative behaviour, involving an abuse or misuse of power or position, which has the intent or effect of making someone feel vulnerable, upset, humiliated, undermined or threatened. Power does not always mean being in a position of authority but can relate to personal strength, the dynamics in a group and the ability to coerce through fear or intimidation. Bullying is usually a regular pattern of behaviour, although sometimes it can also take the form of a one-off incident. |
Harassment | In the UK, harassment is defined by the Equality Act 2010 as (in other countries, definitions may differ) ‘unwanted conduct related to a relevant protected characteristic that has the purpose or effect of creating an intimidating, hostile, degrading, humiliating or offensive environment for the complainant or violating the complainant’s dignity’. Protected characteristics are: age, sex, disability, gender (including gender reassignment), marriage and civil partnership, pregnancy and maternity, race, religion or belief, sexual orientation. Unlawful harassment may also involve conduct of a sexual nature – this is sexual harassment. We define further types of abuse and harm according to the statutory types of abuse in the UK which include, but are not limited to: physical abuse, domestic violence/abuse, modern slavery, discriminatory abuse, organisational/institutional abuse, neglect/acts of omission, self-neglect, cyber-bullying, child sexual exploitation, child trafficking, criminal exploitation/gangs, female genital mutilation, grooming, neglect, online abuse. |
We expect all participants involved in our funded research to treat each other with dignity and respect. ‘Participants’ include:
grantholders
co-investigators
collaborators
research staff and consultants
supervisors
students
sub-grantees and sub-contractors
CRUK funding committee and panel members
Anyone can report a concern about our funded research. Organisations must have processes in place to enable reporting. Section 4.6. below outlines how we handle allegations.
We expect organisations involved in our funded research to prevent harm and address any concerns that bullying, harassment, harm or abuse has taken place or that may arise. This includes organisations to which we provide core funding and those who agree to our grant conditions through a grant application submission (“relevant organisation”). Relevant organisations must ensure that where there are potential risks of harm to those involved in our research, a risk assessment will be undertaken that will consider and mitigate any such risks. Risk assessments are not required at the time the application is made but must be completed before the research starts.
It is the relevant organisation’s responsibility to take these actions:
(i) Have policies in place to prevent and address bullying, harassment, abuse and harm that clearly state the following expectations:
The standards of behaviour and safeguarding responsibilities it expects from staff.
Their procedure for handling allegations, including a clear place to submit allegations to and escalation routes. Investigations into allegations should consider the review, rights and safety of the victim/survivor making the allegation (if they are not the same)
Policies should be available to all staff and students, form part of induction processes and staff training, and ideally published on the host institution’s intranet.
(ii) Make sure that there is an equivalent policy in place at any sub-grantee or sub-contractor.
(iii) Ensure any relevant privacy statement permits the sharing of data in accordance with this policy and that all Participants and relevant organisations have read and are aware of the potential for information sharing.
(iv) Take reasonable steps to ensure the policy is implemented effectively. Reasonable steps may include the following:
Appropriate training for staff and students during inductions and additional training for staff in supervisory roles or for officers dealing with concerns appropriate to their role. Training should be refreshed periodically or in response to any changes.
The establishment of an effective whistleblowing hotline or other mechanism.
Engagement with staff and students on the issue by undertaking awareness raising campaigns and engagement surveys to ensure policies are working effectively and the workplace is free from bullying, harassment, abuse or harm.
(v) Investigate allegations of bullying, harassment, abuse or harm in an impartial, fair and timely manner and take appropriate action. If the organisation is advised by the investigator(s) that a disciplinary procedure is warranted, we expect relevant organisations to complete the disciplinary procedure such that a formal finding can be reached, and disciplinary procedures are applied. The disciplinary procedure should still be concluded even if the subject of the investigation resigns.
(vi) Ensure no agreements are entered into which prevent relevant organisations from telling us of investigation findings and complying with our policy.
(vii) Document the findings of the investigation.
(i) At application stage: when a host institution submits a grant application to us, it must confirm that, other than as notified to us, there have been no findings of bullying, harassment abuse or harm upheld against the lead applicant(s), nor any of its employees or students who are named on the application as proposed participants (defined above in section 4.1.), for which there is an active formal disciplinary sanction for bullying, harassment, abuse or harm.
Where participants are not based at the lead applicant’s host institution, the relevant organisation is responsible for reporting upheld findings directly to us. The relevant organisation should complete the reporting pro-forma template included in the downloadable PDF version of this policy and email it to our Director of Research Operations and Communications at dignityinresearch@cancer.org.uk, telling us if any of the information provided is confidential.
Please also note the information required at application stage in section 4.3.(iii) below. If there has been a finding of bullying, harassment, abuse or harm, we may reject the application where we feel there is continued risk to people or to our principles or ask that the relevant individual(s) be removed from it.
(ii) Where a relevant organisation is responsible for participants, or is involved in our funded research (defined above in sections 4.1. and 4.2.), and a decision is made to formally investigate an allegation of bullying, harassment, abuse or harm, the relevant organisation must inform our Director of Research Operations and Communications when they decide to investigate via the process in section 4.3.(iii) below within one month of deciding to undertake a formal investigation (and must be reported at this stage at the latest) unless the case is deemed high-risk or an allegation is demonstrably irrefutable at an earlier stage, in which case we should be informed immediately.
Where participants are not based at the grantholder’s host institution, the participant’s own relevant organisation is responsible for reporting upheld findings directly to us. We reserve the right to ask for the name of the participant whose conduct is being investigated, where we consider that we have a legitimate interest in doing so. We will reserve any judgement about an allegation until the investigation is complete. We will only provide information to its staff or its external advisors on a need-to-know basis. The relevant organisation must inform us of:
a decision to formally investigate an allegation of bullying, harassment, abuse or harm
the outcome of the investigation and if any sanctions are being imposed
The relevant organisation should complete the reporting pro-forma template annexed to this policy and email it to our Director of Research Operations and Communications at dignityinresearch@cancer.org.uk, telling us if any of the information provided is confidential.
(iii) When notifying us of a bullying, harassment, abuse or harm investigation, the relevant organisation should only provide the following information:
A formal investigation has commenced (notes: as per section 4.3.(ii), we do not require the name of the person against whom the formal investigation has commenced at this point, however, we reserve the right to ask for it. This step is not applicable at the application stage).
Where an allegation has been upheld, the name of the person against whom the allegation has been upheld.
The relevant connection to us (eg our grant reference number or our panel/committee membership if relevant) where this does not identify the person.
A brief factual statement about the nature of the allegation.
The date the allegation was lodged.
The start date of the investigation and the expected/actual investigation completion date.
For completed investigations only: a brief factual statement on the outcome of the investigation, including whether the allegation was partially or fully upheld and any sanctions.
The date of the outcome of the investigation.
The name and position of the relevant HR contact at the relevant organisation (ie the person who is providing the information). We cannot act on unverified, anonymous information.
We reserve the right to request a copy of the investigation report, where we consider we have a legitimate interest in doing so.
While we recognise that the requested disclosures under this policy may include personal data, we consider we have a legitimate interest in handling this data. This requires us to undertake a balancing test to ensure that there are no unwarranted adverse effects on the individual. UK data protection legislation does not prevent the sharing of this data. Whilst we recognise that often information is confidential in nature due to the employment relationship, we maintain the quality of confidence where allegations are under investigation and there is no immediate risk of harm to others. During the application stage, we need to be aware of upheld allegations, so that we can make responsible funding decisions.
After an award has been made, the relevant organisation must tell us when a formal investigation into bullying, harassment, abuse or harm has been started. This is so that we can take the following actions:
Monitor that complaints are being dealt with appropriately and in a timely manner.
Make sure that grantholders receive the support they need.
Be aware of the potential impact on our funded activities and the steps being taken to manage that impact.
Make any necessary onward report required by our regulator (the Charity Commission for England and Wales) and other relevant bodies as required by law.
The information you provide at any point should not include any of the following:
Sensitive personal information (such as special category personal data, as defined in UK Data Protection Law) or information relating to criminal offences or convictions. IIn some circumstances, such information may be pertinent to the investigation. Should a relevant organisation feel that they did want to provide special category data, they should ensure that this meets the requirements of Article 9 of the General Data Protection Regulations, for example, with the consent of the data subject.
Personal details about other people, eg the person making the claim.
Any information you send to us will be treated as follows:
Be handled in confidence and in accordance with data protection law requirements.
Be stored in a secure, restricted-access location, with access restricted to the members of staff involved in the management of these cases.
Be communicated only to our other staff on a need-to-know, restricted-access basis only, where necessary, to pursue our legitimate interests as a funder. This includes making sure of the following:
We can access legal or safeguarding advice.
Grantholders get the support they need from us.
The outcomes of our funded grant activities are not at risk.
We are able to monitor the number of outstanding cases. Our Scientific Executive Board and Research Committee review anonymised data relating to outstanding cases on a periodic basis.
Not be communicated to expert reviewers.
Be kept by us in line with our retention policy, reviewed regularly to assess whether it can be removed, and for no longer than we need it for our legitimate purposes. Any allegations that are not upheld will be stored for two years after the outcome, the remainder will be stored for six years after the outcome, or the point at which any sanction ends whichever is later.
Be communicated to other organisations only where the following applies:
The grant is co-funded by another organisation(s). We may share details of the allegations and its result when known.
We have a statutory obligation to report serious incidents to the Charity Commission for England and Wales or to comply with a court or regulatory order to pass the information on.
We may convene a research conduct review panel – comprising designated senior members of our governance boards – to review the outcome of an investigation and take a decision on what potential, appropriate sanctions we should then take as a research funder (see section 4.5.). Information shared with the panel will be highly restricted, accessible only to those designated senior individuals. All personal data provided will be managed in accordance with our Information Security & Data Protection Policy. Information on how to exercise data subject rights are made available via our privacy statement.
After reviewing the investigation and disciplinary procedure outcomes, we may apply our own sanctions. Sanctions may vary in length, depending on the seriousness of the case and any remedial action already in place. These will be independent of any set by the relevant organisation and will be considered on a case-by-case basis. We may take the following actions:
Send a letter of concern.
Where the person remains in post, they may be required to attend workplace behaviour training before continuing on one of our grants or applying for further funding from us.
Remove the person from the affected grant(s), from our panels or committees.
Withdraw funding from the grantholder. We will work with the relevant organisation to minimise the impact on any staff working on the affected grant(s), which may include transferring the grant to another suitable investigator to allow the work to be completed.
Prohibit that person from acting as a PhD supervisor for students funded by us.
Temporarily or permanently restrict them from future grant applications (or specific types of grant applications) or from being invited to be a member of our panels or committees.
Allow future grant applications, but require the relevant organisation to monitor the way the person manages staff.
Require training and/or monitoring of future work.
Take any further sanctions at its own discretion.
We may apply sanctions against a relevant organisation if we believe the following:
The relevant organisation has failed to respond to a bullying and/or harassment complaint promptly and objectively.
There has been institutional-level failure to complete disciplinary procedures.
There has been a serious Institutional-level failure to effectively ensure appropriate workplace conduct standards are observed.
Sanctions may include the following:
Ongoing monitoring of the relevant organisation’s policies and practices.
Not accepting new grant applications from that relevant organisation for a period of time.
Restricting applications for specific grant types, eg not allowing participation in training programmes.
Suspending funding to the relevant organisation in extreme cases.
Taking any further sanctions at its own discretion.
Anyone can report a concern or allegation of bullying, harassment, abuse and harm related to our funded research. Concerns and allegations should always be reported to the employing organisation, or if this is not known, the organisation that is running the research project. It is the employing organisation’s responsibility to investigate.
If an allegation of is made directly to a member of our staff or via email to dignityinresearch@cancer.org.uk rather than to the relevant organisation, we will take these actions:
One of our senior staff members will first discuss the circumstances with the informant.
We will either encourage the informant to report the allegation at their employing organisation through the appropriate channels or then tell an appropriate individual at the employing organisation if the individual is unwilling or unable to report the allegation directly to the organisation.
We may also pass the allegation to the employing organisation where there is a risk to the safety of others. When this is the case, we do not need to consent of the informant to do so.
We will respect an informant’s anonymity. In exceptionally rare circumstances, we will share their information if required to do so under a court order, if requested by the police or other regulatory or government authority, if it is necessary to protect the vital interests of any individual or if otherwise required to do so by law.
We will tell the informant before we do this. The employing organisation is then responsible for following its own allegation procedures.
We will reserve any judgement about an allegation until the investigation is complete. We will only provide information to our staff or our external advisors on a need-to-know basis.
As stated above, it is the employing organisation’s responsibility to investigate allegations, and this is our preferred course of action.
However, we may:
ask for information about an organisation’s processes and how they are effectively implemented
check that an organisation and any sub-grantee have a policy and are following it
ask for a copy of the full, final investigation report, where we consider that we have a legitimate interest in doing so
This may be done as part of our standard funding assurance process, grants management audits or as part of the annual review process in the case of organisations holding core-funding from us.
If an investigation has been completed and an individual has concerns about the process, we will ask the relevant organisation to confirm that it has adhered to its published policy. We are not able to challenge the outcome of the investigation.
Where we exercise our right to see the above information, we expect relevant organisations to be able to share it. We strongly discourage the inappropriate use of non-disclosure agreements that might prevent organisations from sharing this information with us.
Formal allegations, reports of allegations or complaints about process, should be reported to us, as outlined in this policy, and within five years of the alleged incident.
For any queries about this policy, please contact: dignityinresearch@cancer.org.uk
For more information, please see the following documents/web pages:
