Doing the Right Thing
Experimentation and Ethics at Employment Social Development Canada’s Innovation Lab
Put simply, to be ethical is to do the right thing. At the Government of Canada, the experimentation directive is a call for us as public servants to do the right thing. What I mean is that experimentation with the purpose of rigorously testing the effectiveness of our policies presents an important opportunity for us to keep ourselves to high standards of ethical behaviour as we conduct our work with and for the public. Experimentation grounded in the scientific method, with its use of random assignment, comparison of a change to a control group, and self-correction through iteration, is one of the very best methods to confidently test whether something works or not. I like to think about scientific experimentation as one of the world’s best and most cost-effective risk management tools.
That said, when government policies, programs, and services are insufficiently tested prior to being scaled, we not only run a risk of wasting scarce resources, but also of running into unanticipated adverse consequences for Canadians. For instance, the Scared Straight program that ran in Canada and the United States is a classic example of this type of oversight. This program involved visits to prison by troubled youth, with the underlying assumption that observing prison life and interactions with inmates would scare the youth “straight” from future offending. Three decades after its launch, results from a meta-analysis revealed that the program was not only ineffective, but likely increased delinquency in youth who participated.
If experimentation at the Government of Canada is doing the right thing, how do we do it right? How can we make sure our experiments are ethical? In the academic sector, research projects that involve human participants are submitted to a rigorous ethical review prior to their implementation. The reviews are conducted by a board typically composed of experts in ethics, law, researchers, and members of the public. These committees are the very cornerstone for ethical conduct in research. They provide an independent and thorough review of every step in the cycle of a research project, identifying potential risks and harms, and when necessary, provide guidance as to how risks and harms can be eliminated or minimized. The independence of the committee is key to its effectiveness. The same logic that justifies why medical doctors cannot treat themselves or close ones also applies here: Researchers stand too close to their project so to speak to review them in an unbiased way. In sum, the role of ethics committee is to protect the people who participate in research and the legitimacy of science as a whole.
We as public servants can also benefit from having rigorous ethical review processes that protect those who participate in the research and experimentation we conduct on government policies, programs, and services. National Defence, Health Canada, and the Public Health Agency of Canada — departments that have a high intensity of research and experimentation with human participants — have formal ethics review boards, with clear guidelines and a committee that reviews every research project for ethical acceptability. Other departments that are new to experimentation, such as Employment Social Development Canada (ESDC), are currently without one. Nonetheless, departmental privacy and data protection committees provide clearance for research projects with respect to legal and practical matters regarding privacy and confidentiality. Additionally, some public servants in departments without aresearch ethics review board use a variety of strategies to ensure the ethical conduct of their research for aspects that are not addressed by privacy and data protection committees. For instance, some use ethics review grids from research institutions and consult with academics and other colleagues trained in research ethics.
At ESDC’s Innovation Lab, we sought to take another step forward by developing a framework to better scaffold the conduct of ethical research in our work. First, we adopted the Tri-Council Policy Statement on Ethical Conduct for Research Involving Human Participants (TCPS-2), a guide followed by all major Canadian research institutes, as our ethical bedrock. Second, we developed the following material which could be useful for any group conducting research with the public at the Government of Canada:
- a) an ethics charter expressing our deeply held commitment to the conduct of ethical research
- b) a guide entitled Doing the Right Thing: A Practical Guide for Research Ethics in Government summarizing the main sections of the TCPS-2 in accessible language. It provides a first introduction to research ethics for public servants who have not yet received formal training on the subject
- c) a guide entitled Five Principles for Ethical Experimentation and Nudging in Government addressing common ethical concerns about the use of experimentation and nudging specifically
- d) a user-friendly placemat to help public servants identify whether their project meet ethical considerations for the conduct of ethical research
Additionally, the Lab is establishing a more formalized ethics review process for all its projects. Lab members will be required to demonstrate consideration of ethical issues in any project they undertake. For projects entailing higher risk, they will be required to submit an ethics proposal for external review by an academic expert. These additional procedures are critical given that many of our research projects involve people in vulnerable situations (e.g., youth, seniors, people living with low income).
Lastly, our efforts to socialize the importance of research ethics include a requirement that new Lab members who have not received formal training in research ethics complete the TCPS-2 Tutorial Course on Research Ethics (CORE) during their orientation. This course allows them to acquire a shared language and understanding about Canadian researcher ethics.
Although the processes and strategies mentioned above are useful, they are not a full substitute to a formal review by an independent committee. It is unreasonable to assume that we can anticipate all the potential risks regarding the ethical conduct of our projects. We all have blind spots — that’s just called being a normal human — and like the famous proverb warns the road to hell is paved with good intentions. Additionally, as the need and demand for research and experimentation grows across the Government of Canada, it will become unsustainable to ask academics to review our projects.
And there is also something to be said about an ethics review board allowing us to be freer and more creative, to experiment with bolder, more innovative solutions to the challenges we face. At the moment, we may be holding back on the kinds of interventions we are experimenting with precisely because of our individual perceptions of risk in the absence of an ethics review board. After all, doing the right thing is less daunting when there is a safety net underneath our feet.
Until a formal ethics review board is implemented in departments that are currently without one, we propose a call to action to create an ad hoc volunteer ethics review board. This committee could be composed of public servants from diverse backgrounds, researchers and non-researchers, and would review research projects on dimensions that are not currently addressed by privacy and data confidentiality committees. Some of these include an evaluation of the justification to conduct research with human participants, the informed consent process, the compensation to participants, and an evaluation of potential risks and benefits of the research. Materials and processes such as those used by Health Canada and the Public Health Agency of Canada’s Research Ethics Board could be adapted and used by the committee to support their evaluations.
What are your thoughts about ethics for government research and experimentation with the public? If you conduct research or experimentation with the public, what procedures do you follow to ensure the ethical conduct of your projects? Do you think we need formal ethics boards to review research projects at the Government of Canada? Let us know what you think.
Post by Emilie, Eve Gravel, Ph.D. (Experimentation Works expert).
emilie.e.gravel@hrsdc-rhdcc.gc.ca
Article également disponible en français ici: https://medium.com/@exp_oeuvre
