Ethics review and ethical conduct with respect to ISTLD grant program projects

In our experience most ISTLD funded projects are exempt from ethics review by the Research Ethics Board (REB) under article 2.5 of the Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans, 2010 (TCPS2), as they are considered “quality assurance and quality improvement studies, program evaluation activities, [or] performance reviews.” (See full text of article 2.5 on the reverse.)

If you’re not sure your project is exempt from ethics review under article 2.5, then:

  1. Once your grant proposal is finalized, attach the final full proposal to an email addressed to Hanna Jones-Eriksson or Candase Jensen ( Research Ethics Officers, Office of Research Ethics (ORE) ( asking for a review of the proposal and a decision on whether a research ethics application needs to be submitted to the ORE.
  2. Email subject line should read: ISTLD funded project
  3. A response from the ORE typically takes a week or less.
  4. In the event that a full REB review is needed, the entire process will take longer.

If you need a letter regarding ethics in order to publish your work:

  1. ORE can provide a letter stating why the project did not require ethics review.
  2. If your project is deemed to not need research ethics approval, you may want to ask for an exemption letter at the time you receive the decision from them.

Some conditions under which ISTLD funded projects have required REB approval include those that:

  • explore general questions of scholarly interest;
  • involve many courses across departments;
  • require access to student data beyond that which is captured in a course (e.g. registrar data);
  • involve vulnerable student populations; or
  • directly connect to the faculty member’s disciplinary research.

Regardless of whether or not your project requires approval from the REB, you still must follow ethical procedures, for example (but not limited to):

1. Participation in activities to provide you with evidence/data that are not a regular part of the course (e.g., survey, interview or focus group) must be voluntary on the part of students.

  • We have developed a generic form for requesting student consent for participation.
  • Students who turn in questionnaires can be assumed to consent as long as the voluntary nature of the questionnaire is explained clearly at the top of it. We provide a generic version of such language.
  • If the evidence/data you are collecting is voluntary then there must be no consequences for or impact on students (including their grades) if they choose not to participate.
  • You may use incentives to encourage students to participate in voluntary data collection, but those incentives cannot affect their performance in the course (e.g. impact their grades). 

2. You must respect participants’ rights to privacy and anonymity.

  • When presenting or publishing your findings, do so in aggregate and remove identifying information.
  • If there is any way that a student might be identified by their work, ask them to complete a Consent to Disclose Personal Information Form before presenting or publishing the work.

3. You should be transparent about your study.

  • Inform participants of the study’s purpose.
  • Be clear about any consequences for participating.
  • Explain how data will be handled.

Quality Assurance and Improvement REB Exemption
Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans
(TCPS2, 2010)

The following are directly copied from the TCPS2, 2010:

Activities Not Requiring REB Review

The following distinguishes research requiring REB review from non-research activities that have traditionally employed methods and techniques similar to those employed in research. Such activities are not considered “research” as defined in this Policy, and do not require REB review. Activities outside the scope of research subject to REB review (see Articles 2.5 and 2.6), as defined in this Policy, may still raise ethical issues that would benefit from careful consideration by an individual or a body capable of providing some independent guidance, other than an REB. These ethics resources may be based in professional or disciplinary associations, particularly where those associations have established best practices guidelines for such activities in their discipline.

Article 2.5      Quality assurance and quality improvement studies, program evaluation activities, and performance reviews, or testing within normal educational requirements when used exclusively for assessment, management or improvement purposes, do not constitute research for the purposes of this Policy, and do not fall within the scope of REB review.

Application Article 2.5 refers to assessments of the performance of an organization or its employees or students, within the mandate of the organization, or according to the terms and conditions of employment or training. Those activities are normally administered in the ordinary course of the operation of an organization where participation is required, for example, as a condition of employment in the case of staff performance reviews, or an evaluation in the course of academic or professional training. Other examples include student course evaluations, or data collection for internal or external organizational reports. Such activities do not normally follow the consent procedures outlined in this Policy. If data are collected for the purposes of such activities but later proposed for research purposes, it would be considered secondary use of information not originally intended for research, and at that time may require REB review in accordance with this Policy. Refer to Section D of Chapter 5 for guidance concerning secondary use of identifiable information for research purposes.

Canadian Institutes of Health Research, Natural Sciences and Engineering Research Council of Canada, and Social Sciences and Humanities Research Council of Canada. (2010, December). Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans, pp. 19-20.