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Ethical considerations
in European cross-national research *


Marcia Freed-Taylor

I. Introduction

Social research of any kind is obviously a complex activity. It is carried out within a variety of cultural, legal, economic, and political environments which are bound to influence the research, its scope and its focus. To complicate the issue further, research projects often involve practitioners from different disciplines with their own specific priorities and procedures. When you add to this the aims and requirements of the research sponsors, at times potentially conflicting with those of the researchers themselves, the complexity increases. In these complicated circumstances, the ethical facets of the research process can easily become totally secondary considerations and even the most well-meaning researchers can overlook the ethical aspects of the process.

And yet, in all research undertakings, the consistent definition and maintenance of ethical standards are of obvious importance, particularly so in those types of research where human subjects are involved. Individuals who supply the information which forms the basis of this research have a legitimate concern with the uses to which that information is put and should expect a strict adherence to undertakings of confidentiality given at the time of data collection. Breaches can cause serious limitations in the ability of other future researchers to collect reliable and useful data; they can limit access to the respondents who provide the information required for research as well as access to statistical data collected by others. Research designs and procedures which fail to meet ethical standards and to treat subjects with respect, are likely to result in misleading, inconclusive and biased results. This will be to the detriment not only of the research participants, but of the scientific enterprise and of society as a whole.

In comparative and cross-national research, the problems are compounded. The data subjects must be sure that the information they provide is handled with the same care by every analyst involved in the comparative study. This is by no means straightforward, as national research standards may vary in their stringency and many nations have either differing, or no, data protection laws in force. These differences in research procedures and in the perceptions of both the research community and the society as a whole can make comparative social analysis a highly complex undertaking, and can sometimes sabotage the entire enterprise.

The basic concern is clearly no longer merely a technical one. Making data confidential through implementation of statistical techniques ('masks') which are effective yet faithful to original data is now increasingly possible; control of secondary access and use through electronic gatekeepers and monitors - the data archives and data libraries - is proving effective. The problem facing quantitative researchers involved in cross-national research is, perhaps primarily, an ethical one, which will require acceptance by the international research community itself of the need for common ethical concerns and the assumption by its members of the role of ethically sensitive researchers, responsible data collectors and conscientious data stewards. The key concern is the protection of both the rights of the social community and of the professional integrity of the research community.

This article will highlight some of the ethical dilemmas facing the social researcher, review some of the national, and international, procedures aimed at resolving them and, finally, suggest developments which can assist the cross-national and comparative researcher.

II. The ethical concerns

All social researchers share a number of ethical concerns. These are variously defined and differentiated; as, for example, a series of obligations to society which all researchers must fulfil, obligations to funders and employers, to colleagues, and to subjects (for a full discussion, see Jowell, 1986); or as three major scientific norms that should govern all social research - beneficence (maximizing good outcomes while minimizing unnecessary risk or harm), respect (protecting autonomy of persons), and justice (ensuring reasonable, non-exploitative and carefully considered procedures with fair distribution of costs and benefits) (1). Other divisions exist, with emphases dependent on both disciplinary orientation and, perhaps most importantly, national concerns.

A fuller discussion of these dilemmas must be the subject of another paper, but for our purposes, we can isolate the following basic considerations:

(a) the rights of subjects: the need to protect the statutory rights of members of the social community or groups being investigated, avoiding undue intrusion, obtaining informed consent, and protecting the rights to privacy of individuals and social groups;

(b) the ethical conduct of research: the need to frame research questions and agenda objectively, so as to widen the scope of social research, and to maintain confidence in the research process; to ensure that the conduct, management and administration of research is framed in a way which is consistent with ethical principles and which recognizes the limits of competence of each member of the research team;

(c) sensitivity to cultural and social differences: the need to remain sensitive to, and cognisant of, social and cultural differences and to consider conflicting interests;

(d) reporting of research: the need to report findings completely, widely and objectively, with full information on methodologies employed, both to allow research work to be assessed by colleagues and to increase public confidence in its reliability.

Methods currently in place to ensure that these concerns are confronted can be broadly divided into: 1) the externally imposed, such as legislation, legal, administrative and contractual arrangements, sanctions, or implementation of technical solutions; and 2) those which assume internal regulation, such as educational programmes and the development of codes of professional conduct.

These solutions are, of course, closely interrelated. The existence of one solution may, in some cases, result from the lack of another, or may inhibit the development of alternative solutions. The existence of stringent legislation may, for example, make the development of more self-regulatory trends difficult or impossible. Effective self-regulation may, on the other hand. make legislative or punitive sanctions unnecessary. Legislation may, in still other cases, relate only to research activity carried out in one sector of a community (e.g. the federal or government sector) and not to other quite similar types of activity within the academic community.

The solutions are, in general and perhaps inevitably, only partial in scope, relating to one discipline or type of research. With few exceptions, they relate also only to one particular nation.

III. Externally imposed solutions

We will first deal briefly with those types of regulations which are imposed externally, often from outside the research community itself. They are distinguished from those which lie within the remit of the individual researcher or research team. The most common form of such externally imposed control in the form of legislation - Data Protection Legislation - relates to the protection of the right to privacy of the data subject. It is well known that the procedures contained in the legislation of the various European countries vary greatly, as does the stringency with which they are imposed (2). In many well-documented cases, this national legislation has, while protecting the rights of the individual national subjects of the data, impeded the carrying out of comparative European studies (3). The recent publication of a draft European Data Protection Act by the European Community represents an attempt to overcome some of these difficulties, but brings with it some new potential barriers to comparative research. Until these issues are fully discussed and resolved, it is unclear how these potential legislative barriers can be overcome.

Another type of legislated ethical monitoring is represented by the Internal Review Board, or Human Subject Committee in the United States. Under the National Research Act, such an IRB must be established within each university or other organization that conducts biomedical or behavioural research involving human subjects and receives federal funding for research involving human subjects. The purpose of the IRB is 'to review all proposals for human research before the research is conducted to ascertain whether the research plan has adequately included the ethical dimensions of the project' (4). Failure to meet the ethical standards set by the IRB can result in the withdrawal of all federal research funding from the institutions in question. Similar ethical review committees have been set up by Canadian and Swedish Research Councils, although these are essentially self-regulatory efforts bv the research community itself (5).

Other externally imposed measures include those operated by data brokers and electronic gatekeepers or monitors. Such measures and agencies are designed to ensure that some, at least, of the ethical principles and procedures are not abused and can provide assistance in the administration of sanctions against misuse of research data, particularly statistical data (6). The increasing effectiveness of data archives in performing these functions and controlling and monitoring access to research data has, in fact, considerably eased the problems faced by those contemplating comparative research, both by defusing data collectors' fears that their data will be misused and by facilitating access to the data by centralized information provision and standardization of both data and access procedures. Experiments in which controlled remote access to harmonized confidential data are granted under stringent conditions, such as the Luxembourg Income Study, might provide one model for the future (7). Technical means for ensuring the confidentiality of data and thus the imposition of certain types of ethical behaviour on researchers - are now well established (see Duncan and Pearson, 1991, for a short overview of such techniques). Despite advances in such masking techniques, however, the conflict between the needs for access to statistical information and the demands for confidentiality is obviously still a matter of great concern to all research data collectors. particularly those attached to national statistical agencies. Some of the issues exercising these national representatives are discussed in the proceedings of the International Seminar on Statistical Confidentiality held in Dublin in September 1992 (see Eurostat, 1992). The papers delivered highlight both this continuing concern and, most relevant to the subject of this article, the differing national responses to the problem. Although attempts are being made to standardize procedures, this is still far from reality. Seminars such as this one are, however, a welcome step forward.

IV. Internal or self-regulatory measures

While laws and regulations can avoid the worst abuses of ethical principles,they cannot produce positively ethical research. Responsibility for this lies with the individual researcher. and it is the education and sensitizing of these researchers which will ensure that good and responsible research is carried out. The definition and discussion of the basis of all ethical social science research should, therefore, be the first issue to concern us.

V. A survey of ethical codes

The ethical researcher could be defined as one who is concerned with both the well-being of research participants and with future uses of the knowledge gained, and who accepts personal responsibility for decisions bearing on them. To assess the extent to which professional researchers have recognized such ethical considerations and the need for the maintenance of ethical standards, a survey of research funding bodies, research institutes and centres, institutions and individual researchers was launched in 1993 by the author. The preliminary results of the survey, which is still ongoing, are presented here.

The survey was part of a more general review of codes of professional and research ethics. It was carried out to ascertain the perceived awareness of potential ethical and professional conflicts within the social science research community, and to assess the current coverage of existing codes (8).

The survey was begun in early 1993. A variety of social science research organizations were contacted to ascertain whether codes of ethics and professional conduct had been formulated and were being enforced, and to obtain copies of those which were available. Organizations contacted included social science research funding bodies, professional associations within the disciplinary boundaries covered by the social sciences, and a large variety of academic, quasi academic and public sector bodies carrying out or managing social science research.

Initial enquiries were made of 117 organizations; 65 responses were received, among them 44 organizations which had implemented codes of professional ethics or ethical conduct and who were able to supply copies. Of these latter, two are ethical statements from research funding bodies (the Swedish and Canadian Research Councils), 30 from social science research professional associations (such as the American Political Science and Psychological Associations, the British Social Research Association, the British Educational Research and Sociological Associations, the American Sociological Association, the American Society of Access Professionals, the Canadian Association of University Teachers, the American Association of University Professors and the International Statistical Institute), 11 from research institutions: universities, research centres, and individual departments (such as the University of Cornell, the ESRC Research Centre on Micro-social Change at the University of Essex, the Centre for Educational Sociology at the University of Edinburgh, and the British Universities of Warwick, Surrey and Loughborough).

The majority of codes and guidelines already implemented were provided by organizations in the United States. Few of the major international organizations were able to respond positively, although it is possible that such codes do exist but were not known to those contacted. If true, this would represent a rather worrying state of affairs. Overall, an encouraging interest in the area was noticeable, however. Many organizations indicated that discussion on the subject was taking place and that such guidelines might well be formulated in the future.

VI. Summary of principles in codes of ethics

The general principles of all these codes are concerned with the definition of the substantive questions being considered for investigation and with the decisions made concerning the conduct of the research, the project organization and the methodologies to be employed. All these concerns are of particular relevance to the cross-national or comparative researcher. The principles can be summarized as follows:

1. Acceptance of responsibility: Principal researchers should be fully aware of the ethical issues involved in their proposed research and accept responsibility for all procedures and ethical issues related to the project. In cross-national or comparative research, this is a particularly important issue requiring serious discussion at an early stage in the research project. No common principles or ethical concerns or shared approach can be automatically assumed, and the failures of one member of a cross-national team must be shared by all other members.

2. Conduct of research: Research should be conducted in a way which maintains the integrity of the research enterprise and does not diminish the potential for conducting research in the future. The choice of issues for empirical investigation should be based on the best scientific judgement and on an evaluation of the potential benefits to the participants and society in relation to the risk to be borne by the participants. Research issues should relate to an important intellectual issue; the researcher should be convinced that there is no other way to research the question and provide arguments to this effect.

Research should be conducted in a competent fashion, as an objective, scientific project without bias, utilizing a valid research design taking account of relevant theory, methods and prior findings and all research personnel should be qualified and competent to use any procedures employed in the project. Researchers should undertake an assessment of risks and benefits, and adjust procedures to respect privacy, ensure confidentiality, maximize benefit and minimize risk. In cases where deviation of established ethical principles of specific professions, or those researchers in a particular country is likely, a greater degree of responsibility must automatically be accepted by the individual national researcher.

Research should avoid undue intrusion into the lives of the individuals or communities they study, and should make every effort to protect them from any potentially harmful effects of participating. This issue might well arise in cross-national studies, particularly in those involving communities of widely differing cultures and societies. Specific areas to which applicants should pay particular attention are issues of informed consent, maintenance of full confidentiality of all records, and prevention of disclosure of identities.

3. Awareness of legislation: Researchers should be aware of, and comply with, the requirements of data protection laws and other relevant legislation. This is of particular relevance to cross-national or cross-cultural studies, where differences in national legislation and its implementation can otherwise cause unforeseen problems later in the research, either in analysis or interpretation.

4. Provision of information to others: Researchers should provide adequate information to colleagues to permit their methods and findings to be assessed, as well as alert potential users to limits of reliability and applicability of data resulting from their studies. The individual researcher's own ethical principles should be made clear to allow informed collaboration with other researchers, either nationally or internationally. If external researchers or organizations are involved in the research project, the professional and ethical principles employed should be discussed to ensure their harmonization. If, for example, a number of market research organizations are employed for data collection, reference should be made to the Code of Ethics of the (national) Market Research Society.

5. Cross-cultural research: Researchers undertaking research on other cultures, countries and ethnic groups have a special responsibility to ensure that they make their own research objectives particularly clear, and remain aware of, and respect, the concerns of the individuals or communities to be studied. All research should be consistent with the ethical standards of both the home and host community.

6. Research on groups at risk: When researching individuals or groups in a relationship where a power differential could operate to their disadvantage as subjects (e.g. students, prisoners, employees, minority groups, and the socially deprived), researchers should pav particular attention to issues of consent and potential risk. Particular concerns of consent and potential harm arise in research on children.

7. Resolution of conflicts: If unresolved or difficult ethical dilemmas arise in either the formulation of the research project or in its conduct, assistance or consultation should be sought with colleagues or appropriate committee sponsored by professional associations.

These principles appear in various guises in the majority of the codes, and are, in most cases, intended as signposts rather than detailed prescriptions. At base, it is universally assumed that any deviations from such ethical standards should be the result of conscious decision and not ignorance.

VII. Examples of specific codes

The 50 or so professional codes of ethics studied can be divided into basic broad types: the 'ideal' or 'aspirational'; the 'punitive' or 'regulatory'; and third, the 'educational', neither moralistic nor punitive (see Jowell, 1986).

The International Statistical Institute Declaration on Professional Ethics is of the third type, the 'educational', neither moralistic nor punitive. This type of code is described as being 'based on the twin premises that most ethical issues defy unambiguous regulation and that ethical decisions are matters for the individual rather than the group'. As such, it seeks to describe the current norms of professional practice, to expose the conflicts inherent in the conduct of research, and to give guidance on possible resolutions. Its aim is 'to ensure that individual ethical decisions are informed by professional experience, not governed by professional authority' (Jowell, 1986, pp. 217-9). The annotated Guidelines offer an excellent discussion of the ethical dilemmas facing all types of social researchers, and have been adopted in modified form by a number of other research organizations. They formed the basis, for example, of those of the British Social Research Association Ethical Guidelines, as well as the Statement of Ethical Principles of the ESPRC Research Centre on Micro-social Change at the University of Essex.

Other codes combine elements of more than one type. The established codes of the two funding bodies - the Swedish Research Council and the Canadian Social Science and Humanities Research Council - contain elements of both types, the 'aspirational' and the 'regulatory' codes; the principles outlined are drafted in broad terms (to cover the wide varieties of research potentially funded) but the requirement for the maintenance of ethical conduct suggests ethical review before grants are awarded and consultation with either the Council's own Research Ethics Committee or that of a statutory or semi-statutory Ethics Committee.

The Canadian SSHRC states: 'All SSHRC applicants who propose to carry out research involving human subjects in any discipline must arrange an ethics review. This requirement applies wherever living persons or communities may be affected. . . . SSHRC reserves final judgement in all matters relating to research ethics. The guidelines contained in this booklet are offered to assist both institutional ethics review committees and researchers, whether or not they are funded by the SSHRC . . .'.

The Swedish Research Council recommends consultation with the Research Council's Committee for Ethical Questions in Research in all cases where some doubt exists as to the infringement of the subject's rights. The implication is that all applications are potentially subject to the scrutiny of the Council's Committee for Ethical Questions in Research. The British Economic and Social Research Council is currently considering a draft Code of Ethics, which combines the educational and advisory with the regulatory.

Many professional associations also have ethics review committees, either for resolution of reported conflicts or to answer queries from members. In the US, the National Bureau for Economic Research has instituted a Human Subjects Committee, which is authorized to 'approve or disapprove, or state conditions for, the conduct of any research involving a human subject or subjects, in accordance with the policies stated' (9).

At the other extreme (and closer to the ISA Guidelines), the Director-General of the CNRS in France, François Kourilsky, launched a discussion of ethical principles within the CNRS. A dozen scholars met to construct basic propositions, to be discussed at a seminar in December 1993 focused on 'The Ethics of Scientific Research', with three philosophers in charge of the discussion (see Desplechin, 1993). Responses were sought from national and international specialists, as well as specific testimony from researchers confronted with practical ethical problems in current research activities. One of the seminar leaders, Hourya Dinaceur emphasizes that legislation is not the answer. The aim of the group is not to deliver a moral lecture but rather to offer a framework for thinking on the subject. They are not, they contend, searching for rules for action, but rather for a critical awakening, a conscience éveillé for the creation of a permanent and pragmatic concern with the ethical dimension. Research ethics in France, they contend, will always remain essentially an affair of thought and vigilance, with scientists acting as auto-censors.

These conflicting orientations share one common concern - researchers must become ethically aware. Yet the question remains, much as it does in all discussions of ethical issues. Should, and can, we legislate good behaviour or can it ultimately be reduced to a question of education and personal conscience? Many writers on the subject conclude, with Diener and Crandall, that the definition of 'ideal practices' (or 'wisdom ethics') is most often not realized in concrete situations because of human limitations and competing values and that explicit rules on right and wrong modes of conduct ('content ethics') are impossible because they are not universally accepted by all scholars. This leaves us with 'ethical decisions' which assume that ethical or moral scientists make individual judgements about research practices in light of their own values.

With this in mind, a more informal survey of individual researchers was carried out, in addition to a review of the established ethical guidelines and codes of ethics. This indicated that current awareness of those guidelines and codes which do exist was sketchy. Typical responses were 'I think there is one, but I have no idea what it says'; 'I think I saw it once, but I can't remember now'; 'Is there such a thing? I had no idea'. It is often the case that members of professional organizations or associations sign an ethical undertaking when joining, but these are rarely read or studied in any detail.

Given that it cannot be assumed that one set of principles is universally accepted by all scholars, and given human limitations and competing values and, further, given that researchers from different disciplines and from different countries will not be aware that their standard practices or 'shared norms' are not, in fact, standard or shared, it cannot be assumed that we can rely upon all researchers to behave in consistently responsible ways.

We have seen that many of the surveyed organizations combine guidelines for ethical behaviour (relying on individual self-control) with ethical review committees (offering more impartial judgements and additional perspectives on ethical issues). Operating alongside the self-regulatory codes and guidelines, there are also a number of sanctions which can be imposed on those who break the code or the regulations. These include censure, reprimand and, in cases of serious breaches of ethics, ostracism by professional bodies, through refusal or withdrawal of research funding to withdrawal of public cooperation in research undertakings and, in some cases, a ban from future access to statistical data imposed by data brokers or archives. The threat of such sanctions is most often sufficient to deter researchers from bad behaviour, or, as likely, to remind them of the 'good' behaviour options.

The decisions which face the social researcher are often extremely complicated. To resolve them in a satisfactory way requires a highly developed awareness of the moral and ethical issues. For the comparative researcher, or those involved in cross-national research, the issues become even more complex. We are suggesting a combination of a self-regulatory code, an ethics review committee and recourse to legislative sanctions in the case of serious breaches. The success of this solution depends, however, on two developments. First, the research community must be informed and concerned about ethical issues. To benefit the cross-national researcher, the debate must occur at a cross-national level. Differences in ethical standards and professional approaches must be aired, discussed and, where possible, resolved. Secondly, guidelines and accompanying potential sanctions must be formulated and harmonized across disciplines and across countries. Discussion of such subjects is clearly already on the agenda of a number of cross-national organizations, who are considering formulation of such common standards. To ensure that these reflect the current needs of researchers and of the subjects of the research, the research community must itself take a more active interest and part in this debate.

VIII. Conclusion

With the growth of cross-national, comparative research, and the increase in reliance on international funding for these studies, the need for coherent, relevant and effective European, and international, discussion of ethical principles is becoming urgent. These principles must be accepted, and implemented, by all researchers. Differing legislation relating to research products, as well as proposed legislation limiting free movement of research data throughout the European, and world-wide, research community pose a potentially serious threat to scientifically valid and interesting cross-national research. Only discussion and formulation of shared ethical standards by educated scientists, and the implementation of effective potential sanctions can confront, and overcome, these potential threats. Informed self-regulation and reasoned discussion are essential if externally imposed limitations on research freedoms are not to be too restrictive or punitive.

The following statement concerns a failure of ethical behaviour in engineering research which, it is contended, was a major cause of the explosion of the US Space Shuttle Challenger. It is reproduced here, as it has much relevance to the social research community also.

Whatever the field, the ethical dimension is inherent in its very practice and should never be regarded as a separate or distinct consideration. If it is, the ethical perspective is likely to be postponed until it becomes retrospective, with the investigators and academics looking back to see what went wrong. . . . The need for training in applied ethics, the demand for effective communication - these are now well known themes in the modern organization. Until these subjects are integrated into the curricula, professionals will remain trapped in a vision of their work that is, at best, limited and, at worst, dangerous. (Elliott et al., 1992)

The awakening of ethical conscience demanded by the CNRS team formulating a code of ethics for French social researchers may well be an essential step towards truly comparative research. The minimal aim must surely be that stated by Barnes in 1984 - (researchers must) 'learn to live with an uneasy conscience but continue to be worried by it'.


1. See The Belmont Report for a full discussion. Sieber (1992, p.18) provides a short summary.

2. For a survey of the Data Protection Laws of the European countries, see de Guchteneire and Mochmann (1990).

3. One project, the Panel Comparability Project (PACO) based at CEPS/INSTEAD in Luxembourg is confronting the problems created by differing national data protection and confidentiality laws; while creating a large database of comparable variables from a number of household panel studies, it is able to disseminate only a portion of the database to users outside the project. The project is attempting to obtain dissemination rights for a public use version of the entire database, which involves in some cases modification of national data protection legislation.

4. Sieber, 1992, p.5. This book was written to provide social scientists, their students, and members of research ethics committees with the theory and practical knowledge needed to plan ethically responsible social and behavioural research - and is intended as a 'handbook on how to translate ethical principles into valid research methods and procedures that satisfy both scientific and ethical standards' (Preface, p.xi).

5. For a fuller discussion of these review committees, see the section on Internal or Self-Regulation below.

6. It is possible, however, that the most effective deterrents to misuse of data are the lack of incentive to do so, as well as the lack of sufficient resources.

7. The Luxembourg Income Study (LIS) is organized and administered by the CEPS/INSTEAD in Luxembourg, and contains data from a large number of national statistical agencies. There is some harmonization of data, and stringent controls on access to otherwise unavailable information. For more information, contact LIS at CEPS/INSTEAD, B.P. 65, L-7201 Walferdange, Luxembourg.

8. The survey results were also used as the basis for a first draft Code of Ethics for the UK Economic and Social Research Council.

9. In the Statement of Policies and Procedures Governing the Use of Human Subjects in Research Conducted by the National Bureau of Economic Research.

* Originally published in International Social Science Journal, no. 142, 1994, pages 523-532


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