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Research Complaints and Incidents

Throughout the duration of a research study, investigators are required to report complaints from research participants and research-related incidents to the JRO, as part of the conditions of Ïã¸ÛÁùºÏ²ÊH's decision to deliver (Ïã¸ÛÁùºÏ²ÊH Capacity and Capability) for hosted studies, and as sponsor representatives (Ïã¸ÛÁùºÏ²Ê or Ïã¸ÛÁùºÏ²ÊH).Ìý It is the responsibility of the Chief/Principal Investigator (as applicable), or delegated research staff to report these to the sponsor and participating site.

Complaints from Research Participants

In the first instance, all complaints from participants who are NHS patients should be reported to the NHS Complaints Manager at the Trust where the study procedures or recruitment has been undertaken. Complaints from NHS patients are handled under NHS complaints policies and procedure, with involvement from the JRO where necessary.

Complaints should also be reported to the study sponsor; where the sponsor is Ïã¸ÛÁùºÏ²Ê, the complaint should be reported viaÌýresearch-incidents@ucl.ac.uk; copying inÌýjro.sponsorship@ucl.ac.uk.

Where the sponsor is Ïã¸ÛÁùºÏ²ÊH, the complaint should be reported viaÌýuclh.randd@nhs.netÌý.

Ïã¸ÛÁùºÏ²ÊH Site:
Complaint from NHS patient

NHS Trust Complaint Manager

Ïã¸ÛÁùºÏ²Ê/Ïã¸ÛÁùºÏ²ÊH Sponsored Study:

±«°ä³¢:Ìýresearch-incidents@ucl.ac.ukÌý²¹²Ô»åÌýjro.sponsorship@ucl.ac.uk

±«°ä³¢±á:Ìýuclh.randd@nhs.net

Incidents in Research Studies Hosted by Trusts

Research related incidents are all unintended or unexpected events that could have led, or did lead to harm for participants, staff or members of the public receiving care, delivering services or visiting any Ïã¸ÛÁùºÏ²ÊH site for the duration of the research study. A reportable incident may significantly affect:

a) the rights or wellbeing of a research participant

b) the scientific value of the studyÌý

c)Ìýthe compliance of the study/research staff with relevant legislation, e.g. General Data Protection Regulation (2018) or the Human Tissue Act (2004).ÌýÌý

d) Ïã¸ÛÁùºÏ²Ê or Ïã¸ÛÁùºÏ²ÊH's organizational reputation

Examples of reportable research related incidents are:

  • Incidents/near misses/research concerns
  • Reportable serious adverse events (SAEs) related to the research protocol
  • Suspected unexpected serious adverse events (SUSARs) (for CTIMPs)
  • Serious Adverse Devices Events (SDAE) in Devices Trials
  • Urgent safety measuresÌý
  • Personal Data breaches
  • Protocol violations/serious breach of protocols (where patient safety or data integrity has been compromised)
  • Serious breaches of GCP.Ìý

For Ïã¸ÛÁùºÏ²ÊH,Ìýall research related incidents occurring at Ïã¸ÛÁùºÏ²ÊH should be reported throughÌýDatix, the Trust incident reporting system (available on the Ïã¸ÛÁùºÏ²ÊH intranet myÏã¸ÛÁùºÏ²ÊH); please answer Yes to 'Was this incident related to a clinical trial or research study? When completing the Datix form.ÌýThe incident reporter must also as a minimum provide the study R&D number, study title, and name of Principal Investigator.

For other participating Trust sites,Ìýthe incident should be reported through the respective Trust incident reporting system.Ìý

Please refer to theÌýÏã¸ÛÁùºÏ²ÊH SOP for Reporting and Managing Events and IncidentsÌýfor further guidance.

Incidents in Ïã¸ÛÁùºÏ²Ê/Ïã¸ÛÁùºÏ²ÊH Sponsored Studies

In addition to host reporting requirements, it is important the JRO is informed when an incident has happened on a Ïã¸ÛÁùºÏ²Ê or Ïã¸ÛÁùºÏ²ÊH sponsored research study or trial, this also applies when the study or trial is not hosted at an NHS site.

Please refer to the below reporting streams, and report as per your protocol/sponsor SOPs:

Ïã¸ÛÁùºÏ²Ê Clinical Trials Units (CTUs)Where the study is managed by PRIMENT, CRUK & Ïã¸ÛÁùºÏ²Ê Cancer Trials Centre, MRC CTU at Ïã¸ÛÁùºÏ²Ê, or the Comprehensive Clinical Trials Unit, all incidents should be reported directly to the respective Unit, via their reporting guidance and SOPs
Ïã¸ÛÁùºÏ²Ê sponsored CTIMPs and Medical Device Clinical InvestigationsAll research incidents should be reported to the JRO by emailing jro.sponsorship@ucl.ac.ukÌý
Ïã¸ÛÁùºÏ²Ê and Ïã¸ÛÁùºÏ²ÊH Sponsored non-CTIMPs (JRO managed studies)

Complete and submit the JRO RedcapÌý; alternatively, please email through incident details to research-incidents@ucl.ac.uk.

(Ïã¸ÛÁùºÏ²Ê sponsored studies only) Reporting can also be completed through Risknet, theÌý.Ìý(Click on 'Report an incident'Ìýand select the 'NHS patient' option)

Personal data breaches in Ïã¸ÛÁùºÏ²Ê/Ïã¸ÛÁùºÏ²ÊH sponsored studies

In some instances, despite risk management and mitigations, personal data breaches may occur throughout the duration of the study. The General Data Protection Regulation (2016/679) broadly defines personal data breaches as a security incident that has affected the confidentiality, integrity or availability of personal data. In short, there will be a personal data breach whenever any personal data is lost, destroyed, corrupted or disclosed; if someone accesses the data or passes it on without proper authorisation; or if the data is made unavailable,Ìýfor example, when it has been encrypted by ransomware, or accidentally lost or destroyed.

Ïã¸ÛÁùºÏ²Ê and Ïã¸ÛÁùºÏ²ÊH research reporting requirements:

Ïã¸ÛÁùºÏ²Ê sponsored studies: Personal data breaches or loss of personal data must be immediately reported to the Ïã¸ÛÁùºÏ²Ê Information Security Group (ISG) and the Ïã¸ÛÁùºÏ²Ê Data Protection Officer (as per form and guidance: /legal-services/guidance/reporting-loss-personal-data), and to the Sponsor via the JRO REDCAP incident reporting form.

Ïã¸ÛÁùºÏ²ÊH sponsored studies: Personal data breaches must immediately be reported to the Ïã¸ÛÁùºÏ²ÊH Information Governance team and the Ïã¸ÛÁùºÏ²ÊH Data Protection Officer, and to the Sponsor via the JRO REDCAP incident reporting form.

The following information must be provided:

- full details as to the nature of the breach

- an indication as to the volume of material involved, and the sensitivity of the breach (and any timeframes that apply).

Participating research sites must additionally follow their Trust incident reporting mechanisms, and document any breaches within their TMF/ISFs.