UCL Research Ethics Policy

This policy sets out the core ethical standards that govern all research conducted at UCL.

Introduction
Guiding Ethical Principles
Research Ethics Review
Research Ethics Operating Framework
Research Ethics Committee Core Principles
Responsibilities

Appendix A: Definitions
Appendix B: UCL research ethics strategy and review structure
Appendix C: Risk levels

1. Introduction

1.1. UCL is committed to the pursuit of knowledge to change the world for the better and to ensuring the highest standards of ethics and integrity in all aspects of its research activities. These high standards are essential for maintaining the trust and confidence of its participants, the wider research community, and the public.

1.2. At UCL, everyone involved with research has a responsibility for ensuring these high standards of ethics and integrity throughout the research process.

1.3. This policy aims to promote consideration of the ethical implications of research. Responsibility for research ethics sits primarily with researchers, supervisors, departments and faculties.

1.4. UCL’s Code of Conduct for Research ('the Code’) sets out the principles that those conducting research must abide by in order to meet ethical standards. The Code confirms that ethical concerns must be considered and addressed prior to commencing research and should be regularly reviewed during the research. Where required, a favourable opinion from a committee authorised by UCL must be obtained prior to commencement of research, and researchers are responsible for continued consideration of ethical issues arising over the lifespan of their projects.

1.5. UCL expects all research:

a. To be conducted ethically and to adhere to key ethical standards at the same time as respecting discipline-specific methods and traditions.

b. To follow the guiding ethical principles set out within this policy; expected overall benefit not harm, Voluntary Participation, Informed Consent, Confidentiality and Anonymity.

c. To obtain all relevant institutional approvals, including favourable ethics opinion, and to adhere to all relevant legislation, including local (non-UK) ethical and legal requirements, ensuring that all relevant local approvals, such as favourable local ethics opinion, are obtained as appropriate to the host jurisdiction and nature of the research.

d. To be conducted by researchers who have the requisite knowledge and experience to undertake the proposed research, including ensuring that research conducted by students is appropriate to their level of experience under appropriate levels of staff supervision.

e. To adhere to the UCL Principles of Research Integrity; Honesty, Rigour, Transparency and Open Communication, and Care and Respect.

1.6. To assist researchers with the above, and as part of its commitment to the UK Concordat to support research integrity, UCL will continue to:

a. Support a culture of research integrity.

b. Provide relevant guidance on the requirements for UCL ethics review and how to apply for review and a favourable opinion.

c. Maintain the research ethics webpages to ensure that guidance is readily available and accessible.

d. Identify gaps in, and create additional guidance on, topics and issues as needed for researchers to promote and enable best practice in research.

e. Ensure researchers can access support regarding research ethics and related applications where required.

f. Ensure that internal processes within and across UCL relating to ethical review are rigorous, adhere to accepted standards, and are available and accessible.

1.7. All UCL students and staff, including honorary academic and visiting researchers, are expected to read and abide by this Policy.

1.8. This policy should be read in conjunction with the General Code of Ethical Principles. Researchers also have responsibilities to funders and will be required to follow their relevant disciplinary framework in this regard.

1.9. Being a diverse community means being a place where a wide variety of conflicting opinion and ideas exist and are expressed. Free speech attracts a high level of protection in UK law, and UCL is committed to upholding all speech unless it is restricted by law. Anyone making decisions in accordance with this guidance are required to have particular regard to, and place significant weight on, the importance of freedom of speech within the law, academic freedom and tolerance for controversial views in an educational context and environment, as further detailed in UCL’s Code of Practice on Freedom of Speech (‘the Code’).

1.10. UCL’s policies and procedures will be interpreted and applied in a manner compatible with the Code. For the avoidance of doubt, if there is a conflict between this guidance and the Code, the Code will prevail.

2. Guiding Ethical Principles

The following are guiding ethical principles that are expected to be applied to all research at UCL.

2.1. Expect Overall Benefit not Harm

a. Research involving human participants should strive to have a benefit to society such that the risks involved to participants and others must be balanced against the potential benefit to the overall community. The risks presented by the research should never outweigh the proposed benefit overall.

b. Researchers must consider all the potential risks to participants of the proposed research, whether physical, mental, or emotional.

c. Researchers must consider the potential risks to themselves and the research team through the proposed research, whether physical, mental, or emotional.

d. Researchers should take steps to avoid unnecessary harm by minimising risks, such as adopting the least invasive recruitment methods, and protecting participants from exploitation.

e. Research should be designed to collect data, especially personal (which can identify someone), that is necessary to answer the research question only. Minimising risks can mean collecting data that contains no identifiable information.

f. Researchers should provide justification for the inclusion of vulnerable participants or groups, especially where recruitment is exclusively made up of vulnerable participants, while making research in general as accessible and inclusive as possible.

2.2. Voluntary Participation

a. Voluntary consent of participants to take part in research is essential. Consent should be the decision of the participant and not the result of any undue inducement, coercion or perceived pressure from others to participate.

b. Participants must have the right to withdraw from participation at any time, without fear of reprimand or repercussion.

c. Those lacking sufficient capacity to consent or in vulnerable situations should be supported to express their wishes at the same time as protecting their best interests.

2.3. Informed consent

a. Informed consent is an essential element for the recruitment of participants. To make an informed decision about whether or not to participate in the research, participants should be suitably informed about the research; the aims, methods to be used, what participation involves, risks and expected benefits to them and to others, exclusion criteria, what data is to be collected and how it will be managed, analysed, stored and shared, etc.

b. There may be exceptional circumstances where it is not possible to obtain suitably informed consent from all participants, such as for social media data, covert research or research that relies on an element of deception. Such cases are the exception and must always be explicitly justified, and all steps taken to ensure that the principle of informed consent is met as far as is practicable whilst pursuing the research.

2.4. Confidentiality and Anonymity

a. All participants have the right for their participation to remain confidential.

b. Where participants wish to be identified, or they cannot realistically have their identities kept confidential, a clear record of informed consent must be obtained from the individual participant in advance. This should be stored in accordance with the UCL Records Retention Schedule.

c. Researchers are expected to take all necessary steps to ensure the privacy of participants and their data, including collecting anonymised or fully anonymising any personal data where possible.

d. All personal data should be managed according to relevant data protection legislation and ethical standards, as well as the consent given by participants; this includes accessing pre-collected/archived research data.

3. Research Ethics Review

3.1 The purpose of research ethics review is to support researchers in managing any potential conflicts of interest by considering all the expected benefits, potential risks and the wider ethical implications of the research. Ethics review is based on the notion of proportionality, enabling the level and extent of the review to be conducted according to the level of complexity and ethical risk presented by the research.

3.2 UCL authorises research within the scope of this Policy to proceed without additional executive approval, subject to a favourable opinion from the relevant ethics committee where needed and on the condition that the researchers involved comply with all other relevant aspects of such activity (e.g. compliance with health and safety, safeguarding, and data protection policies)

3.3 All terms used in the following sections are defined within Appendix A.

3.4 All research (including pilot, preliminary research involving data collection and feasibility or exploratory design assessments with secondary data) must obtain favourable ethical opinion if it involves human participants and/or the collection and/or study of data or tissue derived from human participants, except where this is classed as minimal risk (see Appendix C).

3.5 Ethics review is available for research that does not involve human participants, their data or tissue, but raises other ethical issues requiring consideration.

3.6 A favourable opinion from the relevant ethics committee must be obtained prior to the project commencing. A favourable opinion will not be granted in retrospect. The start of a project for the purposes of this policy is defined as the commencement of recruitment of participants, data collection, data use or start of fieldwork rather than conceptualisation of the research idea and the design of the study.

3.7 It is the responsibility of the Principal Investigator or staff supervisor to assess whether the research requires ethics review and ensure that favourable ethical opinion is gained prior to the project commencing. However, all researchers have a responsibility to ensure that the research they undertake has a favourable opinion from the appropriate ethics committee and is conducted according to the conditions of that opinion.

3.8 Researchers should consider ethics for all research; however, some research may be considered as ‘minimal risk’, provided the project does not go beyond the definitions (as set out in Appendix C), and does not necessarily require ethical review unless required at a local level. Departments and Faculties may establish arrangements for the review of minimal risk research.

3.9 It is important to note that minimal risk research is required to comply with relevant Data Protection legislation, so you may need to apply for UCL Data Protection Registration; for instance, accessing the individual participant data, if it is possible to identify individuals from the combination of information being reviewed or your subsequent report.

3.10 Low-risk research ethics applications are reviewed either by an approved Local Research Ethics Committee or by one of the central UCL Research Ethics reviewing committees. Low-risk research may be reviewed by a single committee member.

3.11 All research classed as high-risk (see Appendix C) and/or that falls within UCL’s definition of high risk must be reviewed by one of the central UCL Research Ethics reviewing committees.

3.12 Appropriate detail must be provided to allow for full ethical review of each project. Whilst applications for specific projects are preferred, programmes of research can be reviewed where they meet the following conditions:

a. Applications will not be accepted at high-risk for blanket, generic or programmatic review where applications do not include a narrow and well-defined set of possible methods, tools, participant groups or topics that are not fully defined.

b. At low risk, review committees can review defined programmes of research or module approvals within strictly defined low-risk research parameters where students are using the same well-defined methods on a defined range of topics within the scope of the module. Where projects do not meet the parameters, researchers must complete a separate ethics application for the project to be reviewed.

c. Where a high-risk element involved in an activity repeated over different projects has a clear protocol already approved by a high-risk reviewing committee. For example, a department conducts research which regularly requires skin pick tests but otherwise is low risk. A high-risk committee's favourable opinion can be sought for the defined protocol to be used in low-risk studies to be approved locally.

4. Research Ethics Operating Framework

4.1. The UCL Research Ethics Committee (UCL REC) has strategic oversight of ethical review.

4.2. Research ethics review for high-risk research is conducted by one of two central research ethics committees:

a. Humanities, Arts and Sciences Research Ethics Committee (HAS REC)

b. Life and Medical Sciences Research Ethics Committee (LMS REC)

4.3. Low-risk research is reviewed by one of the two committees detailed above or a Local Research Ethics Committee (LREC). UCL ethics review structure can be found in Appendix B.

4.4. Local Research Ethics Committees must seek authorisation by the UCL REC to conduct ethical review of low-risk research Local Research Ethics Committees are authorised to review low risk research within their department or faculty (for faculty LRECs only). All LRECs must provide annual reports to the UCL REC on request.

5. Research Ethics Committee Core Principles

All UCL research ethics committees must operate in accordance with the UK Research Integrity Office (UKRIO)/Association of Research Managers and Administrators (ARMA) core principles for the conduct of research ethics committees:

5.1. Independence: ethics committees mitigate conflicts of interest, maintain objectivity and avoid bias. Central reviewing committee membership is from a range of disciplines and includes external lay members, a constitution and terms of reference that guarantee freedom to make ethics judgements and reports to the UCL REC, an overarching policy committee for oversight, performance monitoring, and to manage appeals.

5.2. Competence: ethics committees ensure consistent, coherent and well-informed decision-making is upheld through membership, which includes expertise covering the range of research that it reviews. Legal advice is provided by UCL Legal Services. The preparation of ethics applications and workload allocation is recognised as institutional work, and established standard operating procedures and processes are regularly reviewed. Regular training is provided for REC members, drawing on national and international developments in research ethics. RECs will not comment on the science, methodology or design of a study unless they contribute to the risks of a study to participants. RECs will not comment on the quality of research or unnecessarily suppress research which is controversial or poses reputational concerns. Committees will not provide detailed proofreading but will assess participant-facing documents to ensure they are fit for purpose. Committees do not review risk assessments (although relevant content may be included in applications) as that responsibility lies with the relevant department.

5.3. Facilitation: Ethics committees are recognised as facilitating ethically sound research and for providing positive and valuable processes through ensuring a balance of care and enabling and supporting ethical research and innovation. Training is provided to researchers on ethics review, policy and processes to support autonomy and skills in reasoned ethics judgements. Reviews are processed efficiently and rapidly within defined timeframes with appropriate analysis of risk, proportionality of review and with an option for fast-track review. Application forms are clear, requesting only necessary details and guidance, and examples of information sheets, consent forms, invites, and recruitment materials are provided to aid researchers. Opportunities are available for researchers to seek informal advice at any stage of the research. Researchers are encouraged to include the cost of preparing for ethical review when seeking funding.

5.4. Transparency and Accountability: Ethics committees must have clear policies and processes for maintaining high standards of research ethics with clear record keeping and annual reporting.

6. Responsibilities

6.1. There is a range of roles and responsibilities in governing research ethics in addition to the responsibilities of researchers set out above.

6.2. The Head of Department must ensure that staff and, where appropriate, students of the Department understand UCL’s arrangements for research governance and the associated procedures, including:

UCL’s Research Ethics Policy
UCL Code of Conduct for Research
Procedure for investigating and resolving allegations of misconduct in academic research
Declaration of interest policy (in relation to research)
Policy, principles and procedures for the care and treatment of human remains at UCL.

6.3. Heads of Department, or their delegated authority (e.g., an individual with responsibility or a Local Research Ethics Committee), must sign all high-risk applications to confirm the application is fit for ethical review prior to submission.

6.4 Supervisors must review and sign all student ethics applications, whether low- or high-risk, to confirm the application is fit for review prior to submission for ethics review.

6.5. Authorised research ethics committees are responsible for providing an opinion on the research ethics of applications submitted for review.

Appendix A: Definitions

Research

Research: The UK Research and Innovation (UKRI) Economic and Social Research Council (ESRC) defines research in its Framework for Research Ethics 2015 as any form of disciplined inquiry that aims to contribute to a body of knowledge or theory. UCL interprets this to include the generation of new knowledge by students and staff in the context of all areas of academic activity.

Research proposal/project: The proposal or project at the time of submission, as opposed to its component parts. Research project submissions should include all aspects and components of the project, regardless of whether the specific parts require ethical review or not. If any part of the project requires ethics favourable opinion, then the whole project should be described in the submission.

Pilot and preliminary studies: Where there is already a developed set of research questions and a clear starting methodology in place, to be tested on a comparatively small group of research participants with the aim of eliciting whether the method is appropriate. This might include trialling a particular questionnaire or running an activity to be observed. Whatever is being tested, there would be a collection of research data involved. Preliminary discussions do not require ethical review, for example, discussions with community leaders to begin designing the research, to look at research questions, methods, target groups, etc. (the logistics of the process) with informants, where no actual collection of research data is involved. However, the risk assessment would still be required, and the researcher needs to follow any other health and safety requirements.

Project leader: Person responsible for the research; in most cases, this will be the Principal Investigator or the student supervisor.

Public domain: Public domain refers to materials that are irrevocably dedicated to the public domain or are manifestly published/licenced for public use without restriction. This may include websites, social networking content, newspapers, magazines, publications, official reports, and government data. However, not all data available through these sources is necessarily in the public domain (even if publicly accessible) and may be subject to differing ethical and usage expectations on the part of data contributors, and contractual, copyright, and/or other restrictions that must be considered before its use.

Human participants and data derived from human participants

Human participant: Defined as including living individuals, deceased individuals within the last 100 years (cadavers, human remains, and body parts), embryos and fetuses, human tissue, and bodily fluids.

Data from human participants: The ESRC Framework for Research Ethics 2015 defines data derived from human participants as any data derived from individuals as part of a project, or accessing pre-existing data. This includes:

The use of secondary research data, human data and records (such as, but not restricted to, medical, genetic, financial, personnel, criminal or administrative records and test results, including scholastic achievements).
Samples taken from participants, such as blood and DNA (see Human Tissue Act 2004 or the Human Tissue Authority website).
The collection or analysis of passive or “big” data collected via sensors and digital tracking tools, or other online-generated content. Examples of this include accessing data on mobile phone usage, tracking journeys through travel cards, use of online applications such as through online stores or social media.

Research that does not involve human participants or their data but raises other ethical issues

Research that carries a risk, beyond that of mere controversy, to individuals, groups or communities not participating in the research, but who could be impacted due to the topic being researched, or because of the information/data collected, including research that might reasonably be expected to:

Collect accidental human data, e.g. setting video/audio monitoring of animals, environment, weather, etc.
Impact/consequences for individuals/groups, immediate environment, including research that might put restrictions on their environment/land, practices, contribute to pollution or environmental degradation (e.g. establishing protected areas/national parks/quotas for hunting/management of animal species; access to sacred sites, archaeological excavations in disputed territories).
Impact/consequences for individuals/groups' physical and emotional wellbeing, including research into topics where there are particular cultural sensitivities or issues (e.g. historical research into genocides, analysis of sacred objects, research that might cause conflict between different groups).

Appendix B: UCL research ethics strategy and review structure

The UCL REC provides strategic oversight of ethical review processes and holds overall responsibility for research ethics policy, guidance, and procedures at UCL. It reports to the Research, Innovation and Global Engagement Committee (RIGEC).

The UCL REC is supported by 3 subcommittees:

Life and Medical Sciences Research Ethics Committee (LMS REC): Reviews high-risk applications at scheduled meetings and low-risk applications online, where no Local Research Ethics Committee (LREC) is in place. Covers: Brain Sciences, Life Sciences, Population Health Sciences, and Medical Sciences.
Humanities, Arts and Sciences Research Ethics Committee (HAS REC): Also reviews high-risk applications at meetings and low-risk applications online in areas without LREC coverage. Covers: Arts & Humanities, Built Environment, Institute of Education (IoE), Laws, Engineering Sciences, Mathematical and Physical Sciences, and Social and Historical Sciences.
LREC Chairs Group: Provides updates on local review activity, shares best practices, and advises on LREC requirements. This group is linked to 26 Local Research Ethics Committees, which have delegated authority to review low-risk applications.

Further information about the UCL REC and UCL's research ethics review structure can be found on the Research and Innovation Services website.

Appendix C: Risk levels

High-risk

Applications involving the following would be deemed to be high-risk:

Vulnerability
Sensitivity
Deception and covert research
Disclosures
Security sensitive
Researcher wellbeing
Administration of substances
Invasive procedures

Further definitions and examples can be found on the ethics@ucl High-risk checklist (UCL login required).

Low-risk

Applications for research projects which do not involve any of the above high-risk elements can be reviewed as 'low-risk'.

Minimal risk

Applications involving the following would be deemed to be minimal-risk:

Literary or artistic criticism
Archival research from publicly accessible archives
Performance reviews/educational tests
Service evaluation and product and user testing
Audit/quality assurance
Fully anonymous online surveys (non-sensitive topics)
Freely available information in the public domain
Anonymised records and data sets in the public domain
Public behaviour observation (where there is no identifiable data collection e.g. where no recording takes place)
Taste and food evaluation and consumer acceptance
PPI (Public and patient involvement) - Public involvement in the design of research
Evaluation to demonstrate research benefits and impact.
Feasibility/pre-project work, including accessioning datasets to assess feasibility/applicability.
Systematic reviews

Please note that the previous exemption category of 'Research involving the use of educational tests, surveys and interview procedures on human participants in the public area (e.g. elected or appointed public officials, candidates for public office, artists)' will be considered minimal risk whilst under review during the academic year 2025/2026.

Page last updated: January 2026