Rochester Institute of Technology
IN-1: Academy-Industry Connections

3.5.3 Conflicts of Interest Review. In addition to the conflict question on the PRF and as part of the T&C, SRS directs each PI/Co-PI to ensure they have updated their disclosure to remain in compliance with the RIT Individual Conflict of Interest and Commitment (ICIC) Policy as a condition of accepting the terms of the award. If any potential conflict of interest is disclosed on the PRF or in the RIT ICIC system, SRS may need to communicate with the Office of Legal Affairs, any Administrator of RIT's ICIC Policy, or RIT personnel as it conducts its review of the PRF or ICIC disclosure prior to RIT's submission and/or commencement of the research project. The VPR may require project specific special conditions he/she deems necessary to manage any disclosed conflict. In the event a project is Public Health Service (PHS) funded, additional requirements including documentation of PHS financial conflict of interest questions and an online training course will be required prior to the project account being established. Details of the PHS Financial Conflict of Interest (FCOI) procedures can be found at https://www.rit.edu/research/srs/financial-conflict-interest-compliance-procedures-phsnih-funded-awards. RIT expects all applicable project personnel to comply with any additional agency/sponsor FCOI requirements. SRS should be made aware of any questions regarding FCOI compliance related to sponsored projects.

C01.0 EXTERNALLY SPONSORED PROJECTS DISCLOSURE POLICY
I. PREAMBLE

The increasing extent and complexity of scholarship at RIT, especially as it involves student participation, underscores the importance of the university’s general commitment to openness in scholarship. Of particular concern to the RIT Community are projects that receive funds from external sources. To the extent that external funding sources are involved, projects need to be governed by a university oversight policy.

External funding sources may have interests that do not coincide with those of the university. In addition, the interests of individual faculty, who as professionals judge what scholarship ought to be pursued and how best to pursue it, may not always coincide with those of the university or with the interests of students or others. Therefore, the Externally Sponsored Projects Disclosure Policy (the Policy) requires striking a balance among the sometimes contending interests of the individual scholar, the external funding source, students and other participants, and the university. Externally sponsored projects must also conform to professional, ethical, financial and legal standards, as well as contractual conditions specified by the university. Beyond that, no single set of interests can be fully satisfied; at best one can try to further the most important interests while doing minimal harm to the others. To facilitate this process of optimization, there is need for a clear, written policy for externally funded projects based on the principles listed in Section II.
The Policy uses the following terms (defined in Section V): Agreement, Classified Information, Externally Sponsored Projects, University Subsidiary, Pertinent Details, Proprietary Information, and RIT Community.
II. PRINCIPLES

The Policy shall be implemented and administered on the basis of each of the following principles, balanced against one another in a manner best suited to the RIT community:
(1) That there be openness in scholarship -- The principle of freedom of access by all interested members of the RIT Community to the underlying data, to the methodologies, and to the final results of scholarship is important; such data, methodologies, and results should be disseminated through normal scholarly means;
(2) That students and other participants be informed -- Students and any other participants, whether paid or unpaid, shall be informed of the Pertinent Details of Externally Sponsored Projects with which they are involved;
(3) That there be freedom of choice -- Individual faculty, staff, and students shall have the freedom to pursue external funding and to select the projects with which they are involved, including ones that involve Classified Information;
(4) That there be maximum disclosure -- All Agreements involving Externally Sponsored Projects are to be written, with Pertinent Details made a matter of record for the RIT Community;
(5) That there be minimum intrusion -- Any disclosure or review process of Externally Sponsored Projects shall minimize the burden on normal university processes and procedures;
(6) That scholars be responsible -- Those engaged in scholarship are to abide by the university policies and procedures, which includes the definition of scholarship at RIT. They are also to make clear in any publication or scholarly communication the source(s) of funding that made their work possible; they are to honor the terms of the Agreement(s) the university entered into on their behalf; and they are to ensure that the underlying data, methodologies, and results of their scholarship are not represented as having RIT endorsement; and
(7) That there be independent oversight -- A university committee called the Research Compliance Committee (the Committee) which is a standing sub-committee of the university’s Compliance Committee shall ensure compliance with the Policy. This includes considering issues arising under the Policy and reviewing the Policy as needed.