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Action research international

Paper 7:  Rosalie Holian and Robert Brooks (2004)

The Australian National Statement on Ethical Conduct in Research: application and implementation for 'insider' applied research in business



Action research international is a refereed on-line journal of action research published under the aegis of the Southern Cross Institute of Action Research (SCIAR), and Southern Cross University Press

ISSN 1445-6125



Paper 7

Rosalie Holian and Robert Brooks, RMIT Business, RMIT, Melbourne

The Australian National Statement on Ethical Conduct in Research: application and implementation for 'insider' applied research in business


Accepted October 2004



A National Statement on Ethical Conduct in Research Involving Humans was issued in Australia in 1999 by the National Health and Medical Research Council (NHMRC) in accordance with the NHMRC Act 1992. This document was endorsed by the Australian Vice-Chancellors' Committee (AVCC) which is the council of Australia's university presidents, the Australian Research Council (ARC), Australian Academy of the Humanities, Australia Academy of Science, Academy of the Social Sciences in Australia, and supported by the Academy of Technological Sciences and Engineering. The Australian Health Ethics Committee (AHEC) is undertaking a review of these guidelines during 2003-2005. The National Statement can be seen to apply to all research that involves the collection of data from human subjects, as it was signed by the umbrella groups representing research in Australia this implies that all project funded research would be covered, and as all research outputs within Universities are reported to and attract funding from the Commonwealth Department of Education, Science and Technology (DEST) by extension this is similarly covered. There are some boundary issues such as the research/auditing definition distinction and also a recognition that those that involve low risk can have an expedited review.

The focus of this paper is to explore ways in which the ethical guidelines included in the National Statement can be applied in practice to research in business settings. It does not focus on a critique of what was included in the National Statement, or on the merit and value of codes of ethics for research. Our University, RMIT in Melbourne, has undertaken to follow the guidelines associated with the National Statement, as have many other Australian Universities. We understand that similar ethics principles also guide practices in the UK, USA, and other countries. This paper describes how we have tried to apply some basic principles when we advise on and assess applications by staff and students for 'Ethics approval' for research, which we hope will be of some interest and use to others.

When applications for ethics approval are considered by Ethics committees complex issues associated with applied 'insider' research can be raised and some of these may be able to be dealt with, rather than put in the 'too hard' basket. Applied, Action and Practice Based research projects conducted by qualified, skilled 'insiders', with established knowledge, working relationships, access and credibility within the organisation are valuable. Information collected for normal organisational purposes can be a rich source of research data, and ethical research using this may be valued by organisations, academics and the community.



The authors are interested in many wider issues related to ethics, research and the differences between external and insider research, and acknowledge that the feedback from those who read drafts of this paper suggests that several other papers on related topics also need to be written. The ontological and epistemological challenges and support for what may be seen as 'insider' research, and the ways in which this may differ from 'outsider' research are not the focus of this paper, although interesting topics for discussion and debate at another time. Rather, we would like to explore how it seems to us that at least some of the supposed 'ethical' questions that are raised in relation to proposals for insider-research may be based on beliefs and assumptions about the value of any research that is done by an insider-researcher rather than to do with ethical principles. Therefore this paper has a focus on what we have learnt from our experience in implementing the National Health and Medical Research Council (NHMRC)/Australian Health Ethics Committee (AHEC) guidelines when considering ethical issues associated with applied research (often insider action research) in business settings and organizations.

An earlier version of this paper was presented at the 2003 NHMRC/AHEC conference, to what seemed to be an audience largely used to 'Health' rather than 'Business' research. Some of the feedback was "given it is so hard to work out the ethical aspects of this type of insider research why would you bother, isn't it easier to do a PhD or get an academic publication based on different research?" The answer may be "probably yes" however we argue that information that is available in organisations may also be of interest to others, including academics and communities, and so if this can be ethically used for research and published and disseminated this can be seen as a public good. We don't think that potential worthwhile research should be ruled out because it is seen as just too hard to explain to or convince an ethics committee that the research can be done in an ethical way, but recognise that this can be a significant problem for intending researchers. While some data within organisations may not be able to be used there is much that could be, if we are able to carefully pick our way through the potential minefields. This may require a good map, regular stopping and checking on progress, critical friends and other guides to help find a safe passage.

This paper is based on our experiences as members of University Ethics committees, as academic managers and staff advisers, and as supervisors of higher degree research candidates and postgraduate coursework student research projects. Over the past ten years we have worked with managers, staff and students researching aspects of business or work practices in their own organisations. We are also familiar with a number of joint research projects with organisations, industry and professional associations and individual practitioners. Over time we have learned ways to identify ethical issues that may have critical impacts on the viability of a proposed research project. We have also learned how to adapt some methods to address salient issues so that worthwhile research is not needlessly blocked or denied.

We acknowledge that the role of a ideal 'value-free' and 'objective' researcher is an important aspect of some research paradigms, and we also see significant advantages of 'insider' research at some times. These advantages can be due to level of subject matter and cultural knowledge and experience, established credibility and working relationships, legitimate access to otherwise commercial-in-confidence information and conceptual breadth and depth that can be brought to the analysis and interpretation of findings.


Potential for role ambiguity and conflict

Insider research can take many forms, however there are at least two distinctly different types typified by a) Joint Industry/Academic Research and b) Organisational Insider Research. Joint industry/academic research includes projects where industry has invited or engaged an academic as a consultant, often with a contract specifying their role, tasks, outcomes, costs or payments. The contract may be formal or informal, however the role of the academic researcher is largely explicit, has been discussed and often negotiated. The role of a social scientist engaged in applied research that aims to improve work practice is an example of this approach. The ethical issues associated with entering an organisation to deliver a planned 'change program' of this nature have been discussed and taught in university courses over the past 20 years, often based on the work of Mirvis and Seashore (1979, 1982), which is still acknowledged in current Industrial and Organizational Psychology research texts when considering ethical issues of field work (eg: Aguinis & Henle 2002). Their advice that most ethical concerns in organisational research arise from issues to do with roles, and that ethical dilemmas often arise 'not because roles are unclear, but because they are clearly in conflict'; (Mirvis & Seashore 1982, p87) remains sound.

The ethical issues associated with insider research may also differ depending on the type of organisation, eg: whether a Multi National Corporation or one of the 'Top 100', Family Business, Public Sector or Not For Profit organisation, or indeed a University. These may also vary with the organisational role of the researcher and the gatekeeper, and whether these involve a Chief Executive Officer or General Manager, Human Resource Manager, Direct Line Manager, Union Officials, general staff and employees. If the nature of the organisation and work roles of those involved are varied in the case study we present at the end of this paper then aspects of the perceived ethical issues can appear to change.

The principles and practices developed in association with joint industry/academic research do not always necessarily apply to organisational insider research. When the researcher is a member of the organisation with an established role and complex working relationships the issues to do with role definition, role ambiguity, and role conflict are often significantly greater than if the researcher had entered the organisation for the explicit purpose (and temporary duration) of the research. Where the researcher is an existing member of an organisation and may have multiple roles within the organisational context, then role clarification to do with research related tasks, information collection and data analysis is not a simple process. While a conservative approach may be to advise against the research being done by an insider, and in some cases this may be practical and advisable, to routinely or only recommend this option without considering the benefits of insider research to the research, researcher and organisation could be rather short-sighted.


Insider research and Australian National Statement

In Australia the framework for handling ethical issues in research involving data collection from human subjects is set out in the National Statement on Ethical Conduct in Research Involving Humans. The National Statement is comprehensive in its coverage and its preface makes this breadth of coverage clear:

"The National Statement applies to all disciplines of research involving or impacting upon humans, and thus expands the health and medical focus of its predecessor. This is a significant step in promotion of a uniformly high standard for all research involving humans."   National Statement, p.iii.

This quote from the National Statement also makes clear the significant expansion of the coverage of ethics issues, from its initial base in Health and Medical research to cover the breadth of all areas that source data from human subjects. This increase in breadth is the foundation for the present paper. The historical health and medical research focus around ethics is set up on an outsider research basis, that is research where the researcher derives data from participants who are external, or at arms length, to the researcher. As the coverage of ethics issues has expanded into a wider set of discipline areas such as business and management we have moved away from an outsider research focus and towards insider research, for example where the object of the research includes the management practice of the researcher themselves inside their own organisation.

The principles covering ethical research are set out on page 4 of the National Statement. The core principles of: (i) respect for persons; (ii) beneficence; and (iii) justice clearly apply to all types of research. However we argue that the specific implementation of these principles to the ethical approval of research is likely to raise different practical issues in their application in business and management research as distinct from health and medical research.


Issues related to HREC processes

Many HREC proformas and processes seem to have been originally established for traditional pathways of academic research, in many cases to fit with experimental or scientific research paradigms. In the case of applied or social research HREC processes are often based on the premise that the researcher is external, that the research project is initiated and controlled by the researcher, and that there are alternative choices for methods of sample selection. Practice based research by 'insider' researchers does not always fit easily into frameworks based on these premises. One approach has been to advise the researcher to 'act as if they are an external researcher' to as large an extent as possible by following steps that an external researcher may have taken if they were entering the organisation for the explicit purpose of the particular research study.

At times it may be possible for a member of an organisation who wishes to engage in research to attempt to separate their 'normal' work and role from the tasks and processes that will be the focus of the intended research. As Donald de Guerre (2004) has stated "My own experience as an inside action researcher suggests that unless the researcher's employment contract has to do with research, the insider can do everything possible to establish a clear research contract and to secure informed consent, but 'the other' can still perceive the researcher in the old role as they have previously known him or her." He went on to say: "It may be important for inside researchers to be assigned a temporary research project with a new title, move offices etc. such that organization and the researched will take the informed consent seriously?"

In these cases the advice to insider-researchers (and those involved in the management of their candidature if they are also a student) may be to:

I.  Widely advertise the project in the organisation.

II.  Obtain consent from the organisation and participating individuals.

III.  Give participants a genuine choice to opt in/opt out of the research.

However we have some reservations about always or only offering this advice, first because it may introduce additional ethical issues that could increase the perceived risk to participants, and second because it may ignore the benefits of using existing avenues for research. Members of organisations can be well placed to be involved in tasks that can be directly related to a proposed 'research' project as part of the course of their 'normal' work and roles in an organisation.

The approach to advise an insider-researcher to (attempt to) 'act as if' they were an external researcher appears consistent with the National Statement's requirement that:

"The consent of a person to participate in research must not be subject to any coercion, or to any inducement or influence which could impair its voluntary character."   National Statement, section 1.10, p.12.

In an organisational setting there is a strong requirement to be very clear as to the voluntary nature of participation. To be able to freely consent employees in an organization, particularly those with roles that may be dependent, co-dependent or junior to that of the researcher, should not feel even any implicit pressure to be participants in the research. Equally important, where individuals choose not to participate in the research that decision must be fully respected and must not lead to any adverse consequences.

This is consistent with the National Statement requirement that:

"A person may refuse to participate in a research project and need give no reasons nor justification for that decision."   National Statement, section 1.8, p.12.

When there are ongoing working relationships which may have either a positive or negative history and which often involve power differentials between the insider-researcher and prospective participants the decision to participate or decline is not likely to be clear cut. The degree of freedom felt to participate, based on either positive or negative aspects of the relationship between parties could impact on not only the ethics of the research, but also the accuracy of data and quality of the findings. While these issues need to be explored it does not necessarily mean that action/insider research cannot be done in accordance with ethical principles.

Advice to 'act as if' the insider-researcher were conducting an external research project can also be seen as a bias based on what may have been the standard 'academic' approach in the past. The meaning of bias here is to do with habit and a tendency to recommend that one follows what has been accepted as practice based on past approaches without considering inherent differences in the situation faced by insider researchers. The usual steps recommended to be taken by social science researchers, in particular those undertaking a role of participant observer, may be a suitable way to avoid mistakes made in 'covert' research conducted on groups and organisations. However guidelines that were developed to avoid the use of deception by people who were entering a group or an organisation in order to study it do not necessarily apply to insider researchers. They are not merely 'pretending' to be a member of the group or organisation in order to collect research data, their work role and working relationships are genuine. Conducting a separate research project that is not based on normal work is also likely to introduce additional costs in at least time for the organisation, participants and insider-researcher. If there is also likely to be a non-representative sample because of this then this could also reduce the value of the research, relevance of the findings, and potential contribution to knowledge or benefit to the community.

As Davydd Greenwood (2004) has commented:

"Human subjects legislation in the U.S. also began in a similar way and now catches social research and eventually action research in its net. ... My experience at Cornell University was that AR suffers mainly from unintended consequences of a system of protections based in the presumption of an objective relationship between the researcher and the "subjects" and that the aims of the research are not necessarily ethical. Since AR is necessarily informed by a set of democratic and humane values, both in the processes and goals, there is an a priori case to be made that of all forms of social research, AR is less likely to cause harm. ... A number of us at Cornell held a long afternoon discussion with the professor and institutional representatives in charge of enforcing human subjects legislation and this discussion produced a significant improvement in the handling of AR projects. Among the improvements were fewer demands to tell the board what would be done in advance and what the outcomes would likely be."   ARI discussion list, 2004/08/01.

The role of Institutional Review Boards (IRB's) in the USA and the impediments to Action Research that associated requirements and processes can involve have recently been outlined by DeTardo-Bora (2004), particularly when these require what seem to be an overly specific need for details as to the numbers and names of participants, and the interview questions that are to be asked. These requirements are seen as based on positivist-oriented views of research which hinder action research "and if this continues, AR will not flourish. It will be viewed as cumbersome, tedious, and time-consuming"  and this  "would be unfortunate given the wealth of opportunities for practitioners and researchers alike"  (p248).


Ethical questions and insider research

A number of ethical questions may arise when considering the planning of business research to be conducted by an 'insider' who is a member of the organisation. These include:

i)   The nature of the information or data of interest, who 'owns' this, and who can 'release' it for the research purposes requested

ii)   The nature of the relationship between the 'human subjects' who may potentially be involved in the research and the 'researcher'

iii)   The nature and extent of the level of informed consent and freedom to choose not to participate in events or behaviour that may be part of 'normal' work, that could later be included in that selected to be included in the 'research' or research publications

iv)   The nature and extent of anonymity and confidentiality for individuals and the organisation, including between potential participants or 'human subjects' involved in 'normal' meetings or 'special' group discussions for research purposes.

In addition to the issues above, 'insider' research may also have the potential to encounter problems due to unexpected and potentially negative or even dangerous outcomes for organisations and individuals. As Ernie Stringer (2004) said:

"It is insufficient, from my perspective, to merely obtain informed consent, then leave research participants out of the process. As I describe in my own texts (Stringer 2004, 2005), member checking of research procedures need to be an ongoing aspect of the process, so that participants get to check data related to their own inputs, the analysed data, and the draft reports. In this way, they are able to ensure that their perspective or experience is not misrepresented, or framed in ways that may be harmful to them in some way.   ARI discussion list, 2004/07/26.

Peter Petherbridge (2004) comments which are based on forty or more years experience in business management much of which has involved 'prolonged continuous action research' were that:

"[A] potential trap for the unwary researcher (insider or outsider) is the potential for unintended consequences, with the potential to damage reputations and impair relationships [as a] reason for the sensitivity required in handling the ethical issues and gaining the informed consent of all participants - individual and corporate at the earliest stage".   ARI discussion list, 2004/07/25.

Tom Wild (2004) advised that in his doctoral thesis

"which was (in part) a quality assurance project within an organisation using a mix of action research with other case study methods…the consent to publish from the organisation's management and Board was given (in hindsight) without a complete understanding of the ramifications to the organisations future directions and culture."   ARI discussion list, 2004/07/24.

While it is important to be aware of and vigilant about all the concomitant issues associated with 'insider' research we argue that it can be done ethically and may provide useful findings, outcomes and applications. We have seen great research done this way and wish to encourage others to take on this challenge, particularly those who have access to hard earned 'internal' intelligence on how to address and solve practical problems in organisations, and who are passionate about sharing their experience for the benefit of others.


i)   The nature of the 'data'

A key question during the development of an insider research project would seem to be: Does this involve 'organisational data' and/or data about individuals? Organisational data in this sense can be seen as 'business data', which would include information related to organisational targets and measures (eg: sales by product line, market projections), while information about individuals may be 'personally identifiable' information about aspects of behaviour, demographic or other characteristics. Organisational data could be seen to be aggregated data, where the individual data from clients, customers or staff involved is not personally identifiable. Organisational data may be of interest at an aggregated level, which does not require individual detail to be included in the research that examines general trends based on populations of interest or large samples, where data points that are seen to be 'outlying' are discarded as anomalies. It can also be important to distinguish between data that is retrospective, current, or to be collected in the future. Requests for permission to further analyse retrospective data may be simpler to deal with in one way in that it is easier to specify what data is requested, how it will be analysed, and to what end. It may be more straight forward for permission to be given when it is clear to all stakeholders exactly what is to be released and for what purpose. Permission for immediate data collection, whether this uses existing current data collected for 'normal work purposes' or includes additional questionnaires or interviews, or for on-going or future data, as in a longitudinal study, can be open to flexible interpretation and include unexpected inputs associated with a dynamic context or individual participants.

In addition to considering whether the data sought could be classified as organisational and/or individual, it is also necessary to investigate how the data was originally collected and why. While many researchers should now be aware of the need to consider the purpose for which data is or was collected in order to comply with Privacy legislation, they may not always investigate how the data was collected. Some organisations may collect 'covert' information about the behaviour of staff, clients and customers, and while in some cases this may comply with legal requirements the purpose of the data collection may not be consistent with later use for research. It may also be the case that a researcher considers it unethical to use information that was collected covertly or if at all then only with the informed consent of the individuals involved, which may not be possible if the organisation does not permit this disclosure for internal security or similar reasons.

Homan (1991:92) advised that even

"consenting subjects may not have a sufficient awareness of what they are disclosing (as a result of) ways in which consent was only partially informed when it is secured and to the methods by which resistance is eroded or the consciousness of the research act is enabled to lapse."

He also stated that

"What matters much more than the awareness that social research is taking place, however, is the knowledge or assessment of risks and consequences on the basis of which consent is granted or withheld"   (p93)   "For a mind disciplined by practice in the social sciences, it is often difficult to register the point at which incidental observations become purposeful research".   (p99)

Homan (1991:109-113) summarises objections to covertness as that these practices:

flout the principle of informed consent, erode personal liberty, betray trust, pollute the research environment, are bad for the reputation of social research, discriminate against the defenceless and powerless, may damage the behaviour or interests of subjects, may become habitual in the everyday life of the person doing the research, may spread to other spheres of human interaction, are invisibly reactive, are seldom necessary, have the effect of confining the scope of research, and the covert researcher suffers excessive strain in maintaining the cover."

However he also includes a defence of covert methods (p113-119), particularly if the data was collected in an 'un pre mediated' way and then later seen as a useful resource that could be of interest to others if published.


ii)   The nature of the relationship between the 'human subjects' who may potentially be involved in the reasearch and the 'researcher'

Donald de Guerre (2004) suggested that it is important to have

"awareness that participants have a previous employment contract that does not include voluntary participation in work duty"

and comments that from their experience in Canada that

"When the research involves normal work duty for participants, such as action research into effectiveness of some of the new participative planning and policymaking methods, then individual informed consent forms can be signed, but one has to question their validity. It seems to me that this is true whether the researcher is an insider or an outsider?"   ARI discussion list, 2004/07/27.


iii)   Issues of consent

We have also been concerned about the issues of confidentiality and anonymity when there is group or team work involved. Reminders that consent should not be seen as a once-off event are very important, as this is indeed an ongoing process in our experience. It is necessary to consider in advance how practical it is to advise research participants involved in group discussions or meetings that they 'may withdaw from the research at any time, and withdraw any data already provided'. While it is possible to edit data included in transcripts, it is not possible to 'erase' the memories of other participants. The edited transcripts may not make much sense with data from one or more participants removed, and it is difficult to decide what needs to be removed from conversations where other participants follow on from, paraphrase, and refer back to comments made by others present.

Donald de Guerre (2004) pointed out that

"it is common practice to assume that if an individual completes a questionnaire that she has given informed consent. Likewise, if an individual attends a large group process sponsored by an organization that is announced and agreed to by the organization to be voluntary, can one consider attendance in itself informed consent?"   ARI discussion list, 2004/07/27.

Ernie Stringer (2004) advised that:

"Ethical issues also include the use of the products of the research, so that participants should have opportunities to check the way research outcomes are used, and be given opportunities to use research outcomes for their own purposes. Questions of ownership have a central place in discussions about ethics. This is also relevant to the discussion of aggregated data, since all data must be seen to be "owned" by the organization and individuals from which they are derived. It is a question largely about ownership and property rights, rather than confidentiality."   ARI discussion list, 2004/07/26.

The National Statement is clear that: "Before research is undertaken, ... the consent of the participants must be obtained."  National Statement, section 1.7, p.12.

The type of insider research that we are discussing does not appear to fall into any of the exceptions to this principle as documented in the National Statement. It seems that the research element of insider-research may require consent prior to commencement of the research. The complication is that the matter under research, for example daily management practice, has already been separately consented to under a contract of employment. This brings the following issues into play:

(i)  A university ethics committee does not have the ability or authority to alter the daily management practice of an organisation.

(ii)  The fact that a person has consented to certain activities and monitoring on an employment basis does not automatically extend to research undertaken around those activities.

(iii)  Good workplaces will probably conduct quality assurance and audit activity which has been consented to as part of the contract of employment. Again this consent does not necessarily extend to research activities.

There is confusion around these issues. For instance, many aspects of the process of business and management research will overlap with quality assurance and audit activities. In both settings a problem is likely to be identified and analysed and certain changes in practice and process adopted to resolve the problem. A key difference however lies with respect to dissemination of outcomes. 'Research' is usually ultimately targeted to the form of a public outcome in a journal paper, book chapter or thesis. It is fair to argue that this public dissemination of outcomes may not normally be consented to as part of a contract of employment.

The issue of quality assurance and auditing as distinct from research is also characteristic of debates as to ethical research in other discipline areas. The National Statement preamble debates the definition of research as distinct from auditing but as characterises many of these types of debates is unable to reach a firm conclusion. This issue has been taken up at greater length in the Australian Health Ethics Committee (AHEC) paper on when quality assurance in health care requires independent ethical review. The AHEC paper is primarily focused on Health and Medical research. In this setting the AHEC paper states: "Quality assurance activities are not usually intended to lead to publication in peer reviewed journals because the results are usually valid only in the local environment", AHEC paper, section 2.2, p.8.

This differs from quality assurance in Business and Management research where publication is a plausible outcome. The absence of scientific generalisability of results is not a constraint on publication, because generalisability is not necessarily a desired outcome of the research. Instead the research may provide a rich description of the experience of a single case study that is useful in its own right. This does raise an issue as to how the nine questions set out in section 5 of the AHEC paper would apply to the setting of Non-Medical research. In most cases for Business and Management research question 9 as to publication may seem to trigger a requirement for ethics approval and the associated consent of individual participants. Thus in this context the AHEC advice does not seem to generalise to a Business and Management setting.

There is an issue around consent, relating to the fact that in organisational settings consent from multiple individuals may be needed. In this regard, insider organisational research may require consent from the organisation, as well as the individual participants. This is covered by the National Statement as follows:

"In some circumstances consent is not only a matter of individual agreement, but involves other properly interested parties, such as formally constituted bodies of various kinds. In such cases the researcher needs to obtain the consent of all properly interested parties before beginning the research."   National Statement, section 1.9, p.12.

However this section does make clear that organisational consent alone may not be sufficient, what may also be required is the consent of individual participants. While it is entirely appropriate for high level organisational consent to be give, the organisation itself cannot consent on behalf of individuals. What is then required is a separate individual consent from each participant. This is an important difference from the employment setting, and needs to be carefully addressed by insider researchers to make sure that their own personal as well as organisational commitment and enthusiasm for the project does not override individual capacity to meaningfully consent to participation. Insider researchers need to understand that the fact that they have access to data and people for daily employment purposes does not automatically extend to their research, even if this is on their own management practices. Both organisational and participant consent for the research may also be required.


iv)   The nature and extent of anonymity and confidentiality

David Coghlan (2004) has advised that in the second edition of his book Doing action research in your own organization (2005) he had struggled with some of these ethical questions:

1.  If researchers and participants collaborate closely, how can confidentiality and anonymity be preserved? As action research is a political enterprise and has consequences for participants and the researchers it is difficult to guarantee anonymity and confidentiality as others can easily know who participated and may be able to identify who said or contributed what.

2.  If action research is a 'journey' and 'evolves', how can informed consent be meaningful? Neither action researcher nor participants can know in advance where the journey will take them and cannot know to what they are consenting. As a change process can create its own resistance, action researchers cannot be expected to withdraw in the face of opposition (albeit by small groups within the project).

3.  As action research can have political consequences how can action researchers avoid doing harm to participants? The issues of ethics in action research lie in the action research cycle itself. Ethical questions may be posed in terms of possible and actual ethical questions around the cyclical activities of planning, action and reflection. Processes of obtaining consent, ensuring anonymity and confidentiality, balancing conflicting and different needs, are actualized in planning, taking action, collecting data and interpreting.


When does 'normal work practice' become Research?

In the Discussion paper AHEC points out that attempts to clearly separate quality assurance from research are artificial and unhelpful and that what really matters is that:

"quality assurance is undertaken for a valid purpose, and its outcomes are used appropriately; and those who undertake quality assurance adhere to promulgated codes of ethics and relevant laws; and where quality assurance proposals could infringe on ethical principles that have been laid down to guide human research, then independent scrutiny of such proposals should be sought from an appropriate body."   (p25)

The Discussion paper goes on to state that:

"Where a quality assurance study is undertaken with the consent (either written, verbal or implied) of the patient, carer or health care provider or is a 'directly related secondary purpose' which is within the reasonable expectations of the participant and where no burden or harm (physical, mental, psychological, spiritual or social) is likely to result to the participant the study can be undertaken without review by an HREC."   (p26)

If 'as a general rule, quality assurance is regarded as a genuine secondary purpose for gaining access to (identifiable and detailed personal data in) medical records, and this does not require individual patient consent' and there is a 'prevalent view that informed consent is not required under 'controlled' conditions associated with de-identification, minimal risk, and (public) importance'  (Discussion paper, p 18-19)  then it would seem to follow that quality assurance of Business and Management data that is not personally identifiable nor as sensitive as that which may be contained in medical records, may also not usually require individual consent by every individual 'participant'.

The Discussion paper suggests that when

"quality assurance verges on research or it includes identifiable and highly personal data, review by the institutional HREC may be appropriate prior to submission for publication and even prior to the audit being undertaken. In most instances, however, where audits are routine, are clearly explained, and de-identified data is used, institutional management, rather than the HREC, should be the appropriate authority to authorise the audit and review the report prior to publication."   (p24)

This suggests that quality assurance activities related to non-clinical professional/work practices may also be published if authorised by organisational management.

The data collection and analysis conducted in Business and Management as part of normal legitimate work roles in an organisation could be seen as less intrusive for an organisation than a 'quality assurance' exercise that is carried out on medical records by an 'independent' third party who was not a member of the treating clinical team. Organisational level data which may not include personal identifiers can be collected in accordance with relevant laws and codes of ethics. If during analysis this reveals patterns, trends, or information that may be of wider interest to the academic, industry, professional or wider community it is difficult to list in advance what could still be grounds for refusing to allow this to be published. This may need to be checked on a case by case basis and, as the Discussion paper suggests, may usually require only an expedited process for retrospective HREC review of the processes used.

However we suggest that it would be prudent, and from the point of view of members of a HREC committee probably preferable, that if a insider-researcher had reason to believe that they may wish to publish the findings from a planned work activity or quality assurance project in an academic journal, or may wish to use it as input for an accredited study program at a tertiary institution, then they may be best advised to discuss this with a member of the HREC prior to data collection or analysis.

There are interesting challenges that apply to anonymity undertakings in insider research. While it will normally be feasible to protect the anonymity of individual participants through appropriate use of pseudonyms, the protection of company anonymity is more problematic, particularly if the insider research is readily identifiable with the company. Researchers should clearly only provide the anonymity undertakings that they can deliver.

Our advice to insider-researchers who wish to publish their findings and to those involved in the management of the candidature of insider-researchers is to discuss ethical issues associated with the research with an adviser with experience in these matters as early and as often as possible, and again whenever any amendments to the research methodology or methods of data collection or analysis are made. This will assist the development of awareness of ethical issues associated with alternative choices, such as the use of retrospective data, conducting further analysis than usual on current or future 'normal work' data, or establishing a specific research project that may follow steps similar to those that would be used by an 'outsider' researcher.


Insider research and ethics

One of the authors had personal experience of doing insider action research in her own organization, and in doing this learned some hard lessons about role and task ambiguity that have been put to good use since as a basis for some advice to colleagues and postgraduate students conducting insider research (Holian 1999).

Some of issues that may need to be considered are:

i)  Role conflict -- or wearing too many hats (and mantles)

When organisation members speak to an insider researcher 'in confidence' it may not be clear if they are talking to them only as a researcher or also in their organisational role, and merely asking them to clarify this or defining it yourself often does not resolve this problem. After all you are the same person when you walk into another room and perform another role, you can't forget what they told you, and it may have an impact on your decision making.

ii)  Backlash

When a member of an organisation also puts on the mantle (or hat) of a researcher they may give themselves permission to take on a role that is different to the way they would normally behave. This may be a legitimate and useful approach, to try to look with 'fresh eyes', it may also be viewed as acting 'out of character'. The degree of professional distance that may be able to be taken while wearing the researcher's mantle may give the insider researcher a different perspective on their organisation, culture, politics and roles. They may be tempted to talk to other members of the organisation from this position, perhaps to point out the 'elephant in the room', the fact that 'the Emperor has no clothes', that some things that are undiscussable and the fact that they are undiscussable is also undiscussable (Argyris 1990, 1991, 1992). Insider researchers may need to be cautioned and reminded that the research mantle may seem magical and may reveal earth-shattering insights, but it is not bullet proof. Organisational 'suicide' can be a real threat in some situations, and while interesting and useful research may also be able to be done, if it could mean losing one's friends, or job, or both, then the ethical issues of the impact on the researcher may also need to be considered.

iii)  Sensibility

In written applications for research projects in a business context consideration of issues to do with rationale (who cares?) and the validity, reliability and ethics of data collection and analysis are all usually covered. When insider research is involved it can be useful to include another criterion of 'sensibility': does it make sense for the organisation and the researcher to do this? and to do it this way? what other ways could it be done? and are there other relevant and useful questions that could be addressed instead which may be more sensible under these particular circumstances? There are interesting research questions in many fields that cannot yet be fully explored for practical reasons such as how much it may cost in dollars or time or the potential burden on participants, the size limitations of a machine or room, the difficulty of simultaneously examining both structure and function in a living organism. There is also information about what goes on inside organisations that may need to stay within that organisation, and certain work within some roles that may need to be kept to that role, and out of the domain of research, at least for the moment.


A case study: evaluating customer service as an insider-researcher

In this stylised case study the insider researcher is conducting an evaluation of customer service in their organisation as part of a postgraduate research degree. Let us assume that the company systematically collects feedback from its customers and that they research project has two key elements:

  • An analysis of the previously collected feedback data
  • Interviews with staff in the company on how they made use of this feedback data.

The first set of ethical issues that arise are with respect to the use of the previously collected customer feedback data. This data will have been collected in accordance with the ethical standards in the company. These are likely to differ from the National Statement framework around issues of plain language statements and the level of disclosure that is typical of such statements. Thus the issue is whether it is ethical to use this data for the postgraduate research. Clearly the consent of the company is needed and that consent needs to address issues of confidentiality, anonymity and rights to publication. The more troublesome issue is whether the consent of the individual customers is needed. When the data was collected it was explicit, or at least implicit, to customers that the data would be analysed with a view to improving the quality of service. At a broad level this is what is occurring in the present case, although the presentation of results in an academic thesis or paper is probably an outcome that was not expected at the time that the customers provided their data. The privacy legislation can aid in the resolution of this matter.

The second set of ethical issues arise in the interview based data collection from staff. It will be a normal company quality assurance practice to evaluate how to use their customer feedback better, and again in the present case this is broadly what is happening. There are again additional complications that arise for the results of analysing the interviews being written up in an academic thesis or paper. There is a need for consent from the company and the participating individuals, and the employees need to be given a genuine choice to opt in/opt out of the research element. The consent needs to address issues of confidentiality, anonymity and rights to publication.


Advice for researchers, organisations and ethics committees

There are many issues that still remain in need of further discussion and development. It would be useful be able to briefly state what we see as the key issues that we would like to see covered in an ethics application that involved insider research, that would be additional to what is normally/generally required. We have ways of looking at these and ask questions as part of the advisory process but this is usually done on a case by case basis since the organisational context, working/dependency relationships etc vary so much. It would be useful if we could better identify the key issues to assist researchers/students to prepare research and ethics proposals.

Much of our work in this area has involved advice to supervisors of research students, as well as to researchers and directly to students. Others have also pointed out that the ethical issues involved apply to taught Masters dissertations as well as to those doing higher degrees by research. Our university also requires those coursework students who are undertaking research on 'human subjects' to go through the ethics proposal application and approval process, and this means that the staff advising them on their projects also need to understand the many complex issues involved. We haven't as yet found a simple checklist or set of steps that can be used to 'fully train' supervisors or students how to do this, although some guidance on key issues can speed up the process of ethics applications provided there is time for case by case advice on specific unique issues that may be involved. We have been asked many times, 'can't you just give us a few examples of completed ethics application for similar research projects to ours that we can just adapt'? but find that this does not necessarily speed up the process if the key issues are then not adequately considered for this particular researcher in this particular organisation working with this particular information. For some it may all seem to be too hard to understand, think about, and manage, and so they will instead choose to do something else which seems to be a more straightforward and 'easier' path to research and publication.

Our advice for researchers, organisations, and members of Ethics Committees is that when dealing with proposals for insider research in organisations that they consider the ethical issues involved from 'first principles', using a form of the golden rule, asking what is the potential for harm and for good? As part of this consideration there are likely to be issues of consent, and the need to address the question as to when does 'normal work' become research? In addition to considering the issues involved as part of the approval process for research projects to commence, it is also important that researchers, participants and other stakeholders have access to on-going advice, avenues for inquiry or complaints, that there are mechanisms to monitor the ethics of the research processes actually used, and to seek feedback on adverse events, unexpected problems and successful outcomes.

As Davydd Greenwood (2004) has said:

"AR is a necessarily emergent process without a clear predefined goal. AR teams collaboratively set and reset agendas and shift the focus of their efforts as projects develop. Thus what is ethical about AR must be the kinds of guiding processes that manage these dynamics: openness, broad sharing of information, hearing as many voices as possible, not taking risks for other people. The trouble with the existing ethical codes for social research is that they really do not contemplate this kind of "co-generative" relationship among the collaborators and the mutuality of the control of the behavior of both the professional researcher and the other collaborators. Who is in charge often shifts during the process, something most codes of conduct do not contemplate."   ARI discussion list, 2004/08/01.


References and resources

Argyris, C. 1990, Overcoming organizational defenses, Allyn and Bacon, Boston.

Argyris, C. 1991, 'Teaching smart people how to learn', Harvard Business Review, May/June 1991, pp. 99-109.

Argyris, C. 1992, On organizational learning, Oxford, Blackwell.

Aguinis, H. & Henle, C. 2002, 'Ethics in Research', in S. Rogelberg (ed) 2002, Handbook of Research Methods in Industrial and Organizational Psychology, Blackwell, Oxford, UK.

Bruce-Ferguson, P. 1999, Developing a research culture in a polytechnic: an action research case study, Doctoral thesis:

Coghlan, D. 2001, Doing action research in your own organization, Sage, London.

Coghlan, D. (2005) Doing action research in your own organization, 2nd edition, Sage, London.

Coghlan, D. 2004, communication to subscribers to the ARI journal list, as part of the online refereeing process for this paper, 2004/07/28.

de Guerre, D. W. 2002, 'Doing action research in one's own organization: An ongoing conversation over time', Systemic Practice and Action Research, 15, 4, pp 331-349.

de Guerre, D. 2004, communication to subscribers to the ARI journal list, as part of the online refereeing process for this paper, 2004/07/27.

DeTardo-Bora, K. 2004, 'Action research in a world of positivist-oriented review boards', Action Research, 2, 3, pp 237-253.

Ethics forms that a student in the Department of Applied Human Sciences at Concordia is required to complete are at

Evaltalk: An open unmoderated list for general discussion of evaluation and associated issues sponsored by the Americal Evaluation Association. For information see the posting at

Greenwood, D. 2004, communication to subscribers to the ARI journal list, as part of the online refereeing process for this paper, 2004/08/01.

Holian, R. 1999 Doing research in my own organisation: ethical dilemmas, hopes and triumphs, Action Research International, Paper 3, July 1999.

Holian R. & Brooks R. 2003, 'Ethical issues and 'insider' Research in Organisations', paper presented at NHMRC, AHEC, 'Ethics in Human Research' Conference, Canberra, 2-4 April 2003.

Homan, R. 1991, The ethics of social research, Longman, London and New York.

Human research ethics handbook 2001: Commentary on the National statement on ethical conduct in research involving humans, Commonwealth of Australia,

Kushner, S. 2000, Personalising evaluation, Sage, London. (also translated 2002 as Personalizar la evaluación, Madrid: Morata.)

Mirvis, P. & Seashore. S. 1979, Being ethical in organization research, American Psychologist, 34, 9, Sept, pp766-780

Mirvis, P. & Seashore. S. 1982, Creating ethical relationships in organizational research, in J. Sieber (ed), The ethics of social research, Springer-Verlag, NY, pp79-104.

NHMRC – National Health and Medical Research Council:

National statement on ethical conduct in research involving humans, Commonwealth of Australia, 1999

Petherbridge, P. 2004, communication to subscribers to the ARI journal list, as part of the online refereeing process for this paper, 2004/07/25.

Reason, P. & Bradbury, H. 2001, Handbook of action research: participative inquiry and practice, Sage, London.

Report of the 1999 workshops on the National statement on ethical conduct in research involving humans, NHMRC, Commonwealth of Australia, 2000.

Stringer, E. 2004, Action research in education, Pearson/Prentice Hall.

Stringer, E. & Dwyer, R. 2004, Action research in human services, Pearson.

Stringer, E, 2004, communication to subscribers to the ARI journal list, as part of the online refereeing process for this paper, 2004/07/26.

When does quality assurance in health care require independent ethical review? (Draft), A discussion paper incorporating draft advice to institutions, human research ethics committees and health care professionals, NHMRC, August 2002.

Wild, T. (2004), communication to subscribers to the ARI journal list, as part of the online refereeing process for this paper, 2004/07/24.


Glossary / Notes


AHEC -- Australian Health Ethics Committee

The Australian Health Ethics Committee is a principal committee of the National Health and Medical Research Council (NHMRC) established under the NHMRC Act 1992. AHEC monitors and advises on international developments in health ethics issues through liaison with relevant international organisations and individuals, including the World Health Organization (WHO).

The Act establishes that the functions of the Australian Health Ethics Committee are:

-  to advise the Council on ethical issues relating to health; and

-  to develop and give the Council guidelines for the conduct of medical research involving humans; and

-  such other functions as the Minister from time to time determines.

The Minister agreed to the following terms of reference for the 2003-2005 triennium:

-  To develop and give the Council guidelines for ethical conduct in the health field, in addition to those required for functions above, and for the purposes of the Privacy Act 1988.

-  To conduct and promote education and training in research ethics for members of Human Research Ethics Committees and the research community.

-  To advise, support and facilitate the work of Human Research Ethics Committees.

-  To develop, advise the Council on, and apply mechanisms to monitor the use of and compliance with guidelines issued under functions (b) and (1) above.

-  To promote community debate, and consult with individuals, communities and governments on ethical issues relating to health.

-  To keep abreast of international developments in relation to health ethical issues and liaise with relevant international organisations and individuals.

The Australian Health Ethics Committee (AHEC) is revising the National Statement on Ethical Conduct in Research Involving Humans (1999) (National Statement) during the 2003-2005 triennium. The National Statement applies to all disciplines of research involving or impacting upon humans. Given the breadth of its application, the NHMRC, the Australian Research Council, and the Australian Vice-Chancellors' Committee will jointly issue the revised version of the National Statement. These bodies represent the highest level of 'governance' of human research in Australia across all disciplines. The first of two formal consultation processes will begin in the latter part of 2004 and all interested stakeholders will have the opportunity to provide submissions. In the interim, AHEC is keen to receive early comments on the current National Statement, from any bodies with an interest in research involving humans, that might inform the review from the outset. The website:  is to be regularly updated to reflect organisations who have been consulted or who have made public submissions. The contents of submissions will not be published on this website.


Human Research Ethics Handbook 2001, Commentary on the National Statement on Ethical Conduct in Research Involving Humans, Commonwealth of Australia.

The Human Research Handbook is available on the NHMRC Website at:
The primary purpose of the Human Research Ethics Handbook is to help Australian Human Research Ethics Committees (HRECs) assess and facilitate the ethical conduct of research involving human participants and resolve the challenges encountered during this process. The Handbook contains guidance for HRECs in their interpretation and application of the National Statement on Ethical Conduct in Research Involving Humans, thereby helping them maintain and improve the quality of their work. It provides information for researchers on substantive and procedural issues, and is a resource for potential research participants. It is open to the addition of new material and the development of new perspectives and viewpoints. It should be understood that the Handbook is intended to provide information, and explanation. The National Statement remains as the primary and definitive source of ethical principles governing the conduct and review of research involving humans.

The Commentary on the National Statement is designed to explain why a paragraph in the National Statement has been included, identify the ethical premises on which a paragraph is based, suggest how it might be implemented by an HREC or researcher, clarify a questioned interpretation or relate it to another paragraph(s).

The Research Ethics Collection presents the issues confronting ethics committees and researchers within the context of discussions about specific topics and areas of research practice.

The Research Law Collection presents concise and accessible accounts of legal issues in human research.


ARC: The Australian Research Council

The ARC plays a key role in the Australian Government's investment in the future prosperity and well-being of the Australian community. The ARC's mission is to advance Australia's capacity to undertake quality research that brings economic, social and cultural benefit to the Australian community. Established as an independent body under the Australian Research Council Act 2001, the ARC reports to the Minister for Education, Science and Training.


AVCC: Australian Vice-Chancellors' Committee

The council of Australia's university presidents



Authors' contact details:

Associate Professor Rosalie Holian,
Director R&D, School of Management, RMIT Business, RMIT,
GPO Box 2476V, Melbourne, 3000.

Professor Robert Brooks,
Dean R&I, RMIT Business, RMIT,
GPO Box 2476V, Melbourne, 3000.


Copyright © 2004 Action research international, Rosalie Holian and Robert Brooks.  May be used with appropriate acknowledgment for any educational or training purpose without further permission

This paper may be cited as follows:

Holian, R., and Brooks, R.  (2004) The Australian National Statement on Ethical Conduct in Research: application and implementation for 'insider' applied research in business.  Action Research International, Paper 7. Available on-line:


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Maintained by Bob Dick;  this page last amended 20050326