C01.0 Oversight Policy for Externally Sponsored Projects
The increasing extent and complexity of scholarship at RIT, especially as it involves student participation, underscores the importance of the university’s general commitment to openness in scholarship. Of particular concern to the RIT community are projects that receive funds from external sources. To the extent that external funding sources are involved, projects need to be governed by a university oversight policy.
External funding sources may have interests that do not coincide with those of the university. In addition, the interests of individual faculty, who as professionals judge what scholarship ought to be pursued and how best to pursue it, may not always coincide with those of the university or with the interests of students or others. Establishing the Oversight Policy for Externally Sponsored Projects (the Policy) thus requires striking a balance among the sometimes contending interests of the individual scholar, the external funding source, students and other participants, and the university. Externally sponsored projects must also conform to professional, ethical, financial and legal standards, as well as contractual conditions specified by the university. Beyond that, no single set of interests can be fully satisfied; at best one can try to further the most important interests while doing minimal harm to the others. To facilitate this process of optimization, there is need for a clear, written policy for externally funded projects based on the principles listed in Section B.
The Policy uses the following terms (defined in Section E): Agreement, Classified Information, Externally Sponsored Projects, University Subsidiary, Pertinent Details, Proprietary Information, and RIT Community.
The Policy shall be implemented and administered on the basis of each of the following principles, balanced against one another in a manner best suited to the RIT community:
(1) That there be openness in scholarship -- The principle of freedom of access by all interested members of the RIT community to the underlying data, to the methodologies, and to the final results of scholarship is important; such data, methodologies, and results should be disseminated through normal scholarly means;
(2) That students and other participants be informed -- Students and any other participants, whether paid or unpaid, shall be informed of the pertinent details of externally sponsored projects with which they are involved;
(3) That there be freedom of choice -- Individual faculty, staff, and students shall have the freedom to pursue external funding and to select the projects with which they are involved, including ones that involve proprietary or classified information;
(4) That there be maximum disclosure -- All agreements involving externally sponsored projects are to be written, with pertinent details made a matter of record for the RIT community;
(5) That there be minimum intrusion -- Any disclosure or review process of externally sponsored projects shall minimize the burden on normal university processes and procedures;
(6) That scholars be responsible -- Those engaged in scholarship are to abide by the University policies and procedures, which includes the definition of scholarship at RIT. They are also to make clear in any publication or scholarly communication the source(s) of funding that made their work possible; they are to honor the terms of the agreement(s) the university entered into on their behalf; and they are to ensure that the underlying data, methodologies, and results of their scholarship are not represented as having RIT endorsement; and
(7) That there be independent oversight -- A university-wide committee called the Oversight Committee for Externally Sponsored Projects (the Committee) shall ensure compliance with the Policy. This includes reviewing pertinent details of all externally sponsored projects, considering issues arising under the Policy, reviewing the Policy as needed, and reporting to the RIT community annually.
(1) Agreements between external sponsors and the university or a university subsidiary must obtain approval in accordance with a written approval process and must be signed by an authorized signatory of the university. However, the following situations require prior review and shall result in recommendations from the committee to the provost for appropriate action:
(a) requests for a limited level of disclosure of pertinent details;
(b) delays of publications extending beyond ninety (90) days; and
(c) projects that create or make use of classified information.
No request to keep secret the fact of a project’s existence or of its funding source shall be approved.
(2) Pertinent details of all externally sponsored projects shall be reviewed by the Committee and shall be accessible to the RIT community in a format determined by the committee. This record shall be managed by the university office responsible for managing external grants and contracts. Additional information related to all agreements shall be kept on file in the responsible university office, accessible to the Committee upon request.
(3) Detailed procedures for the oversight process shall be available in a document entitled, “Procedures for Implementing and Administering the Oversight Policy for Externally Sponsored Projects.”
OVERSIGHT COMMITTEE FOR EXTERNALLY SPONSORED PROJECTS
(1) The Committee shall: review, develop, and manage procedures for implementing the Policy; conduct educational outreach to students, faculty, and staff; ensure an independent audit record of the Policy every other year; hear complaints arising under the Policy; and make recommendations related to the Policy. The Committee shall deliver an annual report to the president for the board of trustees and to the Academic Senate, Staff Council, Institute Council, and the RIT community. The report shall summarize the degree of compliance with the Policy, recommendations to the provost and subsequent actions, and shall contain a list of annually reviewed externally sponsored projects.
(2) The Committee shall be a standing committee of RIT with its membership appointed by the campus constituent groups, with annual notification to the president and Institute Council. The Committee shall consist of seven members, who hold special obligation to maintain confidentiality:
(a) Two members appointed by the provost, serving staggered three-year terms;
(b) Three members appointed by the Academic Senate, serving staggered three-year terms;
(c) One member appointed by Student Government, serving a one-year term; and
(d) One member appointed by Staff Council, serving a three-year term.
Vacancies that occur shall be filled by appointments from the appropriate campus constituent group, with annual notification to the president and Institute Council.
The university office responsible for managing grants and contracts shall provide representatives to the Committee to serve as ex officio, non-voting members. These representatives shall provide operational support to the Committee.
(3) The Committee shall annually elect its chair from among its members at its first meeting of the academic year; the chair shall be a member of the faculty. The Committee shall meet as necessary to conduct its business, but a minimum of four times during the academic year.
(4) Nominees or appointees to the Committee shall disclose potential conflicts of interest, such as being a consultant to a company that regularly has agreements with RIT. Resumes of all members of the Committee shall be made accessible to the RIT community. Other records accessible to the RIT community shall include meeting agendas and minutes, audit reports, education outreach efforts, event information, and reports of the Committee. The format for all accessible records shall be determined by the Committee.
(5) Complaints and non-compliance issues shall be approached as follows:
(a) Any concerns about the Committee’s operations shall be brought first to the Committee’s attention; then — if unresolved — to the provost; and finally, in the form of a formal written complaint, to the Academic Senate, Staff Council, and Institute Council.
(b) Any concerns the Committee may have about non-compliance with the Policy shall be brought first to the attention of the principal investigator and his/her department head and dean; then — if unresolved — to the attention of the provost; and finally, in the form of a written notice of non-compliance, to the Academic Senate, Staff Council, and Institute Council.
DEFINITION OF TERMS
(1) Agreement means any contract or grant for any study, services, or research between an external funding source and the university or any university Subsidiary.
(2) Classified Information is any information or material that has been determined by the US Government to require protection against unauthorized disclosure for reasons of national security.
(3) Externally Sponsored Projects are studies, services, and research performed by agreement with RIT involving non-university funds or resources. Gifts and resources transferred with charitable intent are not considered externally sponsored projects.
(4) University Subsidiary means any organization which is a wholly-owned subsidiary of the university or one in which the university has majority controlling interest.
(5) Pertinent Details include all of the following:
- name of the principal investigator,
- title of the project,
- abstract of the proposal,
- name of the sponsor and original source of funds (if different),
- amount of the project funding,
- project’s duration, and
- existence of any publication restrictions, classified information, and/or proprietary information.
(6) Proprietary Information is information designated at time of disclosure as private property, including but not limited to trade secrets, patents, or trademarks. Receivers of proprietary information may use it only with the permission of its owner and may not disclose that information without permission.
(7) RIT community refers to persons with email accounts maintained by RIT.
March 10, 1993 - Original Research Oversight Policy approved by the Board of Trustees
November 14, 1996 - Education Committee of the Board of Trustees approved procedural changes
January 21, 2002 - Executive Committee of the Board of Trustees approved procedural changes
January 16, 2007 - Executive Committee of the Board of Trustees adopted Oversight Policy for Externally Sponsored Projects (replaces Research Oversight Policy)
Edited August 2010