Electronic communication for the purpose of recruitment of research participants

1. Definition of electronic communication

For the purposes of this policy, electronic communication, refers to unsolicited email messages distributed to recipients within the University of Southampton (‘the University’) community. 
Examples of messages include emails sent from generic or specifically created distribution lists to all members of a group, or multiple groups, such as: all students, all staff, all staff within a department, all staff or students within a faculty, or groups of individuals with a specific remit/responsibility.

2. Purpose

There has been increased use of electronic communication across the University by both students and staff. Although two guidance documents covering the use of ‘mass emails’ are currently in place there is widespread confusion and misunderstanding leading to complaints and delays.

This document also includes information on alternative University managed electronic communication methods which can be utilised for the purpose of research recruitment and provides best practice principles for drafting and distributing emails whether addressed to the University community or externally.

3. Scope

This Policy applies to all University staff and students, including any individuals affiliated to the University who use (or are asked to use) University managed electronic communication methods for recruitment of university staff and students as research participants.
This policy does not cover recruitment of participants using other electronic methods (such as social media) or recruitment of participants outside of the University.

4. Data protection

The University expects all staff and students to comply with the Data Protection Act 2018 (DPA) and the University’s Data Protection Policy.
University email addresses are considered to be the personal data of staff and students to whom they were issued. Therefore, use of these email addresses must comply with the DPA and Data Protection Policy. 
University email should be used in accordance with the University Acceptable Use Policy. 

5. University ethics review and approval processes

All Research projects involving human tissues, human data or animals must be registered and approved via the University’s online platform ERGO II1(Ethics and Research Governance Online) or via the Professional Services AREQA platform.     

The sponsor and/or ethics review requires the researcher to state and justify the proposed recruitment methods in the submission questionnaire.
To determine if the proposed recruitment method is appropriate the Reviewers will consider the:

• suitability of the communication channel for the recruitment message in question
• number and profile of the target participant group in comparison to the membership of the proposed mailing list
• importance of not overburdening recipients with emails of limited relevance or interest to them

All staff and students must observe the University’s Research Ethics Policy, and conduct their research to the highest standards of ethics and research integrity.

6. Recruitment of research participants

Staff and students are expected to select a research recruitment method most appropriate to their study. For more information, please see recruiting participants.

The use of unsolicited emails is NOT an acceptable method of recruitment of research participants.

However, the University does acknowledge and recognise the need for researchers to reach wide audiences within the academic community and therefore does encourage the use of other wide-reaching methods, including the following methods.

Opt-in Distribution Lists

These lists may be set up by Faculties or certain University groups or societies to enable staff and students to receive information related to a specific subject matter. If a particular list is set up to facilitate communication of research projects, it can be used for recruitment of study participants. Staff and students must voluntarily subscribe (opt-in) to these lists and be given an option to unsubscribe at any time.

Electronic Notice Boards

Electronic Notice Boards such as SUSSED or Faculty/Professional Services SharePoint sites can be used for posting a variety of university related messages, including approved invitations to participate in research projects and surveys. These invitations or information notices should be limited to a brief message with a link to where more information can be found.

Note: Use of Blackboard to recruit is not acceptable

University, Faculty or Professional Services issued Electronic Newsletters

Electronic Newsletters are suitable for dissemination of research related information if it is relevant to the subject matter of a particular newsletter and necessary authorisations have been obtained as per section 7. Typically, this should involve just a short message with a link to where more information can be found.

Note: electronic newsletter used for this purpose would need to be included in the ethics submission and reviewed before being posted.

7. Authorisation of the use of electronic communication

Authorisation of the use of electronic communication will only be considered on an exceptional basis for studies of institutional or national importance.  

Staff and students planning a research project must first consider the various communication channels (as outlined above) and the most appropriate target audience for their message.

The method selected and the justification must be fully documented within the ethics application
Reviewers will consider the information provided in the application to determine if the recruitment method is appropriate or is further information is required.

Researchers are only allowed to use the exact methods described and approved in their ethics submission to recruit participants to their study.

Unsolicited emails are not an appropriate recruitment channel. In the event that a researcher makes a justification for the use of unsolicited emails, the application would need to be reviewed and approved by the University Research Ethics Committee. This would only be considered on an exceptional basis for studies of institutional or national importance.

8. Administrative Research Ethical and Quality Assurance (AREQA)

Any institutional or administrative research conducted to inform the business activity of the University (i.e. research which does not form part of the mainstream academic research undertaken within University faculties) by the University’s Professional Services (for example, institutional research, student services, or human resources) requires approval via the Administrative Research Ethical and Quality Assurance (AREQA) process.

The following are examples of situations which are considered a legitimate business purpose and therefore direct emails would be permissible:

1. The distribution of official or national surveys which are a requirement from our funding or other oversight bodies (for example, UK Research and Innovation, Office for Students, Quality Assurance Agency for Higher Education), or that feed into key league tables that the University considers strategically important. Examples of such surveys include, but are not limited to the following:

• National Student Survey
• Postgraduate Taught Experience Survey 
• Postgraduate Research Experience Survey
• Graduate Outcomes Survey

2. Certain University commissioned surveys and service evaluations undertaken to assess performance of our teaching, research, and core operational activities. Feedback from staff and students is important for institutional planning, decision making, and policy development. Engagement with staff and students can improve their experience at the University, bring new innovations to the way the University operates and help us remain a dynamic and constantly improving organisation.

3. Invitations to participate in research or events of great institutional or national importance, for example, related to public health or security, in which the University is involved.

Further information on AREQA Approval can found at: Administrative Research Ethics and Quality Assurance (AREQA).

9. Electronic communication best practice

In exceptional circumstances, where electronic communication for the purpose of recruitment of research participants is allowed and authorised as per Section 7 above, the format of the message should follow the examples of good practice as set out as follows:

• All communication messages must conform to the relevant University policies and regulations including: Research Ethics Policy, Data Protection Policy, and IT policies.
• Personal email accounts must not be used for sending out emails when conducting University business or research.
• Recruitment methods must not use personal email accounts.
• Communication should only target the groups of people who are likely to be interested in the message content and/or for whom the content will be appropriate.
• The subject line of the message should have a meaningful, appropriate, and clear title. For example: Recruiting for Study X or Your chance to Participate in Study Y.
• Staff and students should be given an opportunity to decide whether they want to participate in the particular study or survey. The message should be therefore self-explanatory, as brief as possible, and contain a link to the full information about taking part. The individual’s consent must be appropriately obtained before they can start the survey or participate in research.
• To limit the effect on the University network, the message should be sent as plain text and should not include attachments.
• The message should clearly state who is the sender either in the ‘From’ field, and/or include contact details within the message for those recipients who have questions or require further information.
• Individual email addresses of multiple email recipients must be hidden from all other recipients. This can be achieved by using the ‘Bcc’ (blind carbon copy) field instead of using the ‘To’ and ‘Cc’ (carbon copy) fields. The sender’s email address should be added to the ‘To’ and ‘From’ fields. 
• Whenever any approved communication message is sent via the appropriate University email distribution list it should offer an option to unsubscribe from the mailing list where possible. Any responses to the opt-out must be fully respected and documented.

10. Related policies and further information

• University Research Ethics Policy
• Data Protection Policy
• University IT Policies
• Research Integrity, Compliance and Trusted Research 
• Administrative Research Ethical and Quality Assurance (AREQA)

11. Guidance review

This Policy will be reviewed regularly, and at least every three years.

12. Version control