Quality management system (QMS) information
Document type Directive |
Area of management Corporate Secretariat |
|
Original date of issue 2021-03-23 |
Status Final |
Effective date 2020-09-10 |
Review frequency Every 3 years as required |
Date of last review 2020-09-10 |
Authority
Approval Secretary General |
SEC has issued the governing policy, and this directive aligns within the authority of that policy. |
Accountability Director, Corporate Secretariat and Senior Ethics Officer |
The Director and Senior Ethics Officer has the accountability for implementation of the policy via the directive. |
Ombud and manager, Ethics, Integrity and Respectful Workplace |
The Ombud and manager has the responsibility to ensure consistent application and operational execution of the directive at the procedural level. Enquiries: |
1. General direction
1.1 Objectives
The directive is intended to assist NRC employees in implementing the public communication of research and scientific information (s.7.4) and dissemination or research and scientific information (s. 7.5) provisions of the National Research Council of Canada (NRC) Research and Scientific Integrity Policy (RSIP). The directive outlines the approach to be taken in the public communication and dissemination of research and scientific information and the applicable review process.
1.2 Principles
As expressed in the RSIP, the NRC encourages its employees in the public communication and dissemination of science both with professional audiences and with the broader public. Trusting that employees will act in the organization's best interest in matters relating to the public communication and dissemination of research and scientific information, in the interpretation and application of the Policy and this directive, the NRC will ensure that processes are intended to address significant risk, will be kept simple and expeditious, and will recognize the diversity of NRC's Research Centres, Branches and IRAP (CBI).
The NRC recognizes
- the right of employees to freedom of expression on matters of research and science
- that the manifestation of this freedom of expression exists within constraints such as the NRC's responsibility to safeguard intellectual property, Protected or Classified information, client and partner confidentiality, and all relevant legislation, regulations, policies, and agreements (contractual or otherwise)
- the important role of employees in communicating research and scientific information to professional colleagues, to decision-makers, and to the public
- its duty to serve the public interest in the communication and dissemination of research and scientific information in the appropriate forum
This directive is informed by the definitions, concepts, and values set out in the RSIP and is subject to the provisions of relevant policies, regulations, and laws as listed in sections 4 and 5.
1.3 Application
The directive applies to all NRC employees and other people working for the NRC as defined in the RSIP.
2. Directive requirements
2.1 Roles and responsibilities
What are the NRC's obligations to employees?
NRC senior management should, in respect to the public communication and dissemination of research and scientific information:
- encourage employees to communicate research and science with their peers and broader scientific communities, both internal and external, as well as with the broader public
- provide services and repositories to enable the effective management and disclosure of research outputs, including publications and associated metadata and data sets
- encourage fair, efficient and transparent processes to support expeditious dissemination of research and scientific information
- provide training to support employees in the protection and management of the NRC's intellectual property
NRC CBI management should, in respect to the public communication and dissemination of research and scientific information:
- enable employees to communicate research and science with their peers and broader scientific communities, both internal and external, as well as with the broader public
- ensure the use of services and repositories to enable the effective management and disclosure of research outputs, including publications and associated metadata and data sets
- establish fair, efficient and transparent processes to support expeditious dissemination of research and scientific information
- seek employee review and approval, the purpose of which is to ensure accurate representation of their work prior to public communication and dissemination
- ensure employees have access to training and support in the protection and management of the NRC's intellectual property pertaining to the communication and dissemination of research and scientific information
What are employees' obligations?
Employees are expected to diffuse research and scientific information. To enable expeditious review by management, employees should notify their manager, at the earliest possible stage, of their intention to communicate and disseminate research and scientific information and the intended channel for dissemination.
Employees should ensure that their public communication and dissemination of research and scientific information:
- strive to present and characterize the uncertainties, potential biases, and knowledge gaps associated with research or scientific evidence
- adhere to all relevant legislation, regulations, policies or agreements (contractual or otherwise) and peer review as appropriate
- adhere to Government of Canada and NRC policies and guidelines with regards to treatment of Protected or Classified scientific or research information or intellectual property, including the NRC Information Security Guide and NRC Intellectual Property Policy
- identify any comments or recommendations on or explicit discussions about federal statutory, regulatory or policy matters
- adhere to NRC information and data management policies, principles and practices
- clearly indicate if and when they are speaking as a representative of the NRC for the record and public attribution
- identify appropriate venue(s) for the dissemination
- respect Indigenous data and information management protocols to ensure community consent, access and ownership of Indigenous data and informationFootnote 1
The responsible author(s) of any research or scientific communication must ensure that:
- approval of all listed authors and contributors is obtained
- all authors share responsibility for the work in question and are prepared to defend the aspects of the research in which they were directly involved
- authorship is discussed at the earliest possible phase of the research and issues are addressed well before the writing of a manuscript
- the work in question is not a republication of original work except when the republication involves translation or dissemination to diverse audiences and is consistent with existing standards on republication, including, for example, the publication of reviews
- all contributions to the work are appropriately acknowledged in a manner conforming to accepted standards of the relevant discipline(s) and publication(s)
- the NRC authors' federal affiliations are listed
- the communication has been subjected to appropriate independent peer review and that technical and/or editorial changes that may result from this review have been addressed
- matters related to acknowledgements and official languages have been appropriately managed and administered
- the possibility of publishing in open access journals for scientific and technical papers has been explored
- they have exercised due diligence in ensuring that all issues related to the Public Servants Inventions Act, intellectual property and related matters have been resolved
- they understand relevant terms and conditions for publication, including copyright and level of authority required for approvals
Moreover, employees should seek credible and reputableFootnote 2 outlets for academic publication that conform to established practices and standards of academic publishing, including particularly rigorous peer review practices.
2.2 Review processes
Communications that meet the following criteria do not require prior review with CBI management. In such cases, NRC employees should provide management or other relevant personnel a copy of the communication, for information purposes only.
Criteria:
- Explanations and descriptions of a researcher's scientific findings when previously published or otherwise made public under due authority
- Explanations and descriptions of the published or publicly available scientific findings of others when communicated in a non-partisan and non-political manner and in the capacity of a recognized expert
- Opinions on scientific and technical issues alone when clearly identified as such whether communicating in professional fora or in public environments
All other public communication and dissemination should undergo prior review with CBI management.
Employees should discuss planned dissemination activities with management at the earliest possible time, e.g. when planning a research project. In addition, managers should review drafts of research and scientific information prepared by employees prior to public communication and dissemination.Footnote 3
The purpose of this review is to discuss the following considerations and determine if they apply, and then determine appropriate next steps:
- Identify any relevant statutory, regulatory or policy matters that could impact the planned communication or dissemination
- In consultation with NRC's National Program and Business Services Branch, identify potential copyright, patent or other intellectual property considerations, including whether a business or commercialization opportunity exists, that may preclude or delay disclosure
- Assess whether the information is Protected or Classified, as defined in the NRC Information Security Guide
- Identify whether the information is confidential to a client and/or requires client review prior to communication/dissemination
- Identify potential conflicts with existing legislation, regulations, policies or agreements (contractual or otherwise)
- Determine cost requirements for communication/dissemination
- Assess information management requirements and, open science and open data opportunities
- Confirm that NRC work is published in accordance with the standards of responsible authorship listed above in section 2.1 What are employees obligations?
- Determine if the communication respects the Guidelines on the conduct of Ministers, Ministers of State, exempt staff and public servants during an election (commonly known as the "Caretaker Convention")
- Share, in writing, feedback that does not interfere with the research and scientific integrity of the proposed communication;
- Identify any relevant training or administrative support required for the employee, mainly when acting in the capacity of official spokesperson
- Identify any requirement for formal management approval
In accordance with sections 7.4 and 7.5 of the RSIP, formal management approval is required, prior to submission for publication, communication, or dissemination:
- for the public communication of any Protected or Classified business, research or scientific information
- if a research or scientific publication or other dissemination format contains explicit comments about, or recommendations on, federal statutory, regulatory, or policy matters
2.3 Formats of public communication or dissemination
Formats of public communication or dissemination may include, but are not limited to the following examples.
- Dissemination of scientific publications or other formal reports on research or scientific work conducted by NRC employees:
- journal articles
- monographs
- edited books
- book chapters
- technical, research or scientific reports
- annotated databases and associated metadata
- research or scientific notes
- newsletters
- posters
- other communications using research or scientific content irrespective of the medium (audio, video, print or online)
- Public communications of research or scientific work conducted by NRC employees:
- responses to public inquiries
- public lectures, presentations, or seminars
- public panel discussions
- media briefings and interviews
- opinion pieces, either in print or online
- contributions to NRC, professional, society, media, non-governmental organization, or business newsletters or websites
- blog posts and contributions to social media platforms
- Public communications in the capacity of a designated NRC spokesperson
- All scientific and technical reports including summaries of research and associated analyses that pertain directly to federal statutory, regulatory, or policy matters
3. Definitions
Classified information: As per the NRC Information Security Guide, this includes plans, intentions or proposed policies relating to the national interest, which are not intended to be disclosed.
Communication (of science): As defined in section 9 of the NRC Research and Scientific Integrity Policy.
Dissemination of research and scientific information: Communication that includes research or scientific content and that is designed for a knowledgeable, often technical, audience in any medium (audio, video, print, social medial and other online platforms) as well as all formal reports on research or scientific work conducted by NRC employees and secondary data and information as well as reports incorporating and citing the relevant research or science work carried out by other federal agencies, provincial, municipal or indigenous governments, international organizations, academic institutions, business or civil society. Examples of dissemination are available in section 2.3 of this directive.
Protected information: As per the NRC Information Security Guide, this includes information for which unauthorized disclosure, destruction, interruption, removal, or modification could reasonably be expected to cause injury to an individual, organization or government which lies outside the national interest.
Public communication of research and scientific information: Communication that includes research or scientific content and that is designed for a general, non-technical audience, in any medium (audio, video, print, social medial and other online platforms). The target audience may have limited ability to critically evaluate the scientific merits of the information. Examples of public communications are available in section 2.3 of this directive.
4. Related NRC policies
- NRC Research and Scientific Integrity Policy
- NRC Information and Data Management Policy
- NRC Policy on Conflict of Interest and Post-Employment
- NRC Intellectual Property Policy
5. References
- NRC Code of Conduct (2013), including the Values and Ethics Code for the Public Sector
- Public Servants Inventions Act
- Copyright Act
- Access to Information Act
- Privacy Act
- Security of Information Act
- TBS policies governing the management of information, data, technology, access to information, privacy protection, communications, etc.
- Guidelines on the conduct of Ministers, Ministers of State, exempt staff and public servants during an election
- Social Media Guidelines for NRC employees
- NRC Information Security Guide
- Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans (TCPS 2) Chapter 9
- Setting new directions to support Indigenous research and research training in Canada 2019-2022.