Non-standard application processes
The Imperial Research Codes of Practice page maintains a list of the areas of research which may be prohibited or restricted in some way. However, some research may require additional approvals or considerations during the proposal development phase.
Whilst the majority of proposals follow a standard application process or contract negotiation, there are a number of factors with potential for complexity which may delay Institutional Authorisation to submit the application or execute the agreement if not established and considered in the early stages of proposal development.
The application may fall into one of the following categories:
A restricted / quota call
When an external funder restricts the number of applications that may be submitted per institution, an internal process is coordinated and put in place by the Funding Strategy team in the Research Office. Each process is defined by the particular restrictions of the call and is communicated as appropriate through the Faculties and added to the list of current managed calls.
In response to an internal call
In instances when institutional level awards are made to the Vice-Provost (Research) for internal distribution, the Funding Strategy team in the Research Office* will consult, as appropriate for the award, Faculty Research Strategy Managers, other Research Office representatives, Faculty Research Services Managers and Faculty Finance Officers to agree supporting processes including communication (timeline, scheme rules and requirements) and will make scheme specific guidance available. Many of these type of awards are advertised on the internal funding opportunities webpage.
* For awards made by the NHS, such as the BRC scheme, the same process will apply but be coordinated and communicated by the Faculty of Medicine’s Research Strategy Manager.
To fund a Research Centre or Institute
A ‘Bid Manager’ will be required to coordinate the development of the application to ensure consultation with all parties to establish a properly scoped, costed, priced and authorised research bid. The Bid Manager will most likely be a member of the lead academic department and may (but not necessarily) be the Principal Investigator.
To be submitted to a new funding body and / or funding scheme
The terms and conditions of funding must be reviewed by Faculty Research Services as part of the internal approval process. In the case of new funders and / or funding schemes, extra time may be required to review the terms and conditions before the proposal can be submitted to the Funder.
If the College has not received funding from an organisation before, Accounts Receivable (AR) will first need to be undertake a credit check before the new funder can be set up on the College’s finance system. Faculty Research Services will also carry out an ethical assessment of the new funder. These checks must be satisfactory before an award is formally accepted.
Need to be stated in a foreign currency
Project costs should be converted to the appropriate currency in accordance with the College’s Foreign Currency Policy.
Further information can be found on the Funding in a Foreign Currency webpage.
The research project may fall into one of the following categories:
Require institutional contributions / commitments and associated statements of support
The Funding Strategy team in the Research Office will provide institutional statements of support where required and appropriate to the bid. Letters of support from the President, Provost or Vice Provost (Research) can be provided on request after assurance that the proposal is of appropriate quality, fits the remit of the call, and that any financial commitments on behalf of the College included in the proposal have been agreed by the budget holder. In such cases the Bid Manager must ensure that:
- the Funding Strategy team is informed of the intent to apply;
- all appropriate approvals are obtained in good time;
- the Funding Strategy team is given sufficient time (at least 10 working days) to review the bid and a draft letter of support prior to the submission deadline.
Involves external organisations such as other UK universities or overseas organisations
The development of multiple partner bids must be initiated several months before the funder deadline and where College is the lead, responsibility for their coordination is designated to a nominated Bid Manager. The lead institution will be responsible for coordinating all elements of proposal development including: defining the research scope / plan, costing and pricing (informed by third party costs), reviewing / negotiating the funding terms and conditions, oversight of tendering requirements, executing sub-agreements and subsequent project/account management (unless delegated through a formal agreement, e.g. collaboration/consortium agreement).
Due to the complexity of some research collaborations the negotiation of related subcontracts and Third Party Agreements can be a lengthy process. Principal Investigators should notify their Department and Faculty Research Services at the earliest stage of proposal development to avoid subsequent delays.
Many of the College’s main funders require lead institutions to carry out Due Diligence checks on third parties undertaking grant-funded activities to evaluate the risk of collaboration and determine the partner’s ability to deliver the planned work programme. These assessments are particularly important if the proposed work involves potentially higher risk organisations (UK and Overseas).
Research involving non-UK partners should be in line with the College’s International Strategy (and region-specific strategy if in existence). Projects involving any of the following should be referred to the International Relations Office:
- Formation of a consortium involving overseas universities or research institutes outside of those funded by the European Commission Framework Programmes
- The creation of a physical presence abroad (e.g. institute, research centre, etc.)
- Clauses on UG/PGT/PGR exchanges, CPD or other educational provision abroad
The project (or an element thereof) will be carried out off-site
Where Imperial led research is to be undertaken off-site (as opposed to sub-contracted or collaborative work being undertaken at an external organisation) implications such as additional indemnity or insurance cover and third party agreements should be considered. This is particularly important for clinical studies where there may be additional eligibility and approval considerations (e.g. researcher eligibility to conduct healthcare studies on the relevant NHS sites (honorary contracts), NHS approval, co-sponsorship etc.). Further guidance can be found on the Research Governance and Integrity website.
Involve creation of new buildings and / or major modifications to existing buildings and installation
Projects requiring capital investment must follow Estates – Project Management policies and procedures. These requirements must be carefully considered prior to submission of the proposal to the funder.
Involve humans, their tissue and / or data (i.e. healthcare research)
'Healthcare research’ means all health related research involving humans, their tissue and/or data.
Guidance on regulations, principles and standards of good practices can be found on the Research Governance and Integrity website.
Involves accessing material which is subject to the Nagoya Protocol
The Nagoya Protocol on Access to Genetic Resources and the Fair and Equitable Sharing of Benefits Arising from their Utilization to the Convention on Biological Diversity (the Protocol) aims to ensure that owners or guardians of genetic resources receive a “fair share” of any benefits that arise from research conducted with those resources.
The Nagoya Protocol came into force on 12 October 2014, and has been signed by over 50 countries including the UK and the EU. The protocol applies to genetic resources, traditional knowledge associated with genetic resources; and the benefits arising from the utilization of such genetic resources and associated traditional knowledge. It also applies to any organismal research or collection storing organismal life. It covers research disciplines indirectly linked to biosciences, such as earth or climate science (GR in drill cores, water, or soil samples) and archaeological sciences (archaeobotany, archaeozoology, and archaeology), and, could apply if these samples are used for sequencing, e.g., for ancient DNA. It does not apply to genetic resources covered by specialised access and benefit-sharing agreements such as the International Treaty on Plant Genetic Resources for Food and Agriculture, or the framework for pandemic preparedness of the World Health Organisation.
For further information please see the page What is the Nagoya Protocol?
Involves the processing of personal data or sensitive personal data
If you are processing personal data or sensitive personal data as part of your research you will be subject to General Data Protection Regulation (GDPR) implications and you may need to complete a Data Impact Assessment form (DPIA). Please see the data protection pages on Research data on the Legal Services website for more information or contact the Data Protection Officer for more information.
Requires non-NHS ethics approval (i.e. non-healthcare research)
Non-health related research involving human participants and/or their data and high-risk educational research that is undertaken by College staff or students may still require ethics approval. Further guidance can be found on the Science, Engineering and Technology Research Ethics Committee (SETREC) webpage.
Involves animal research
At Imperial College London animals are only used in research programmes where their use is shown to be necessary and unavoidable. Imperial is committed to the principles of the 3Rs (replacement, refinement and reduction) and therefore researchers must always consider alternatives and only proceed when these cannot be found.
The College as a whole holds a Home Office licence for animal research, and each researcher who works with animals and each new project involving animals requires a separate Home Office licence. Applications to conduct research that involves animals is overseen by ethical committees. An ethics review must be completed before any research involving animals is undertaken. More information can be found on the Central Biomedical Services webpage (restricted access), or by contacting Imperial's Animal Welfare and Ethical Review Body (AWERB).
The project and/or the relationship of the parties involved fall into one of the following categories:
Be considered ethically unsound, a reputational risk or sensitive
The College is committed to operating to the highest ethical standards. The Ethics Code sets out the conduct expected from the College community to promote and support good ethical behaviour. Research that compromises the College’s independence, objectivity of judgement or reputation must be avoided. Within the context of proposal development; research proposals and related agreements must not compromise the College’s commitment to honesty, integrity and fairness.
Proposed relationships with third parties (e.g. research funders and collaborators) should be considered within the context of the College’s Ethics Code and Relationship Review Policy, and potential risks should be documented and escalated within the defined framework.
Research that may involve or generate materials, methods or knowledge that may be considered ethically unsound, sensitive or may be misused (e.g. research which could be misused for criminal, terrorist or unethical military purposes, such as development of materials and technologies that could be used in weapons production, operation or dissemination) may not be entered into without fully documented risk assessment and appropriate referral / escalation. In some cases the research may be prohibited. More information can be found on the Imperial Research Codes of Practice page.
Involve persons whom could be perceived as having a conflict of interest
Any arrangement that may constitute a real, perceived or potential conflict of interest relating to any College / connected person within the scope of the project (e.g. an Investigator in receipt of an associated consultancy) must be referred to the appropriate authority for consideration in line with the College’s Conflict of Interest policy and funder’s requirements.
The National Institutes of Health have their own Financial Conflict of Interest policy which covers a range of requirements such as mandatory training, disclosure of significant financial interests and reporting to NIH. A number of key responsibilities are assigned to Investigators, Heads of Department, Faculty Research Services / Joint Research Office and the Research Office.
Involves the export and communication of sensitive technology which could be used or modified for military use, or where end-use concerns exist
UK export controls are designed to restrict the export and communication of sensitive technology or strategic goods, which have or may have military application, with the aim of preventing weapons of mass destruction (WMD) proliferation and countering international threats such as terrorism. The Controls apply equally to the academic community as to any other exporter, and cover physical export (tangible items), electronic transfer, non-electronic transfer (which may include verbal), or transfer by any other means, thus encompasses non-tangible tranfers (eg. software and technical know-how) as well as physical items such as equipment.
The Controls are managed by ‘lists’ which specify equipment or technologies that are sensitive or present a proliferation risk. Where a transfer or export falls under one or more of these lists and the Controls a licence may be required in order to continue, or in extreme circumstances the transfer may not be permitted to take place. Export controls and any licences required are administered by the Export Control Organisation (ECO). There are few exemptions to the requirement to obtain an export licence for controlled technologies, most notably the ‘basic scientific research’ exemption, which will cover a majority of university activity, however, it is prudent to always check whether a licence is required. It should be noted that failure to obtain an appropriate licence to export controlled goods may result in a criminal offence being committed.
In some cases the research may be prohibited. More information can be found on the Imperial Research Codes of Practice page.
For details on how to apply for a licence please see the Export Controls page.