Ethical and Legal Concerns
When participating in CARRA activities, it is your responsibility to understand
and adhere to NCI's policies regarding conflict of interest, confidentiality,
and lobbying during CARRA activities.
This section answers the following questions:
What Do I Need To Know About Conflict of Interest?
Definition: Conflict of Interest
A conflict of interest is a situation when you, a family member,
friend, or other associate is in a position to gain or lose personally,
professionally, or financially from an action that might be taken by NCI.
Actual Conflict of Interest
An actual conflict of interest arises in which a CARRA member has or would have
official responsibilities with an outside organization with which the CARRA
member has a financial interest (his/her own or an interest that is imputed to
the CARRA member) or affiliation. Such a situation puts the CARRA member in the
position of having an official responsibility or action which could directly
influence his or her own financial interests or those interests that are
imputed to him or her (financial interests of spouse, minor children, outside
employers, and other entities).
Apparent Conflict of Interest
An apparent conflict of interest arises when a CARRA member is involved in a
particular matter involving specific outside parties (including individuals and
corporate entities) and the circumstances are such that a reasonable person
with knowledge of the relevant facts would question the the CARRA member's
impartiality in the matter.
The most common types of actual conflicts of interest include
If you suspect a conflict of interest, immediately inform the
Activity Contact
working on that activity.
Examples of Conflict of Interest
The following are three examples of conflicts of interest:
Example 1:
You have been asked to serve on a peer review panel and have been assigned 15
proposals to review. In advance of the review meeting, you receive a list of
applicants, institutions, and collaborators for all proposals being considered
by the review panel. You notice that an individual from an organization on
whose board of directors you serve is listed as a principal collaborator for
one of the proposals, although it is not one of the proposals that you have
been asked to review.
Is There a Conflict of Interest?
Yes, you do have a conflict of interest with the one proposal
that involves the organization for which you serve as a board member. The
conflict exists because the organization's financial interests are imputed to
you by virtue of being a member of the board of directors. You should contact
the Activity Contact for the review panel immediately.
What Will Happen?
You will not be asked to step down from the review panel. You will be asked to
leave the room during the review of that one proposal for which you have a
conflict of interest.
Example 2:
You are going on a site visit as part of an evaluation of a cancer center's
application for continued funding. You receive a package of materials to review
in advance of the visit. In reviewing the material, you run across a familiar
name, that of your oncologist, when you were first diagnosed with cancer 10
years ago.
Is There a Conflict of Interest?
No, but there is an apparent conflict of interest. You must call
your Activity Contact for that activity immediately.
What Will Happen?
As a member of a site visit team, you must avoid any actions that appear to be
a conflict of interest, even though no actual conflict exists. Because the
oncologist at the cancer center is your former oncologist, judgment must be
applied on the question of the strength and frequency of the relationship
between you and your former oncologist. You should not participate in the site
visit review of any individual with whom you've had a recent personal or
professional relationship. If you've had no contact with your former oncologist
in the past ten years you may be permitted to participate in the site visit.
However, if you have remained in touch with your former oncologist, you will
not be permitted to participate on this particular site visit review team, but
you will be asked to participate in a future site visit of another institution.
Example 3:
You are asked to participate in the review of a book chapter focusing on the
emerging role of consumer advocates in cancer research. In reviewing the
Activity Profile, you notice that your advocacy organization is co-sponsoring
publication of the book with NCI.
Is There a Conflict of Interest?
Yes, you have a conflict of interest, even if you have not been
involved in the co-sponsorship activities or book development in any way. You
must call your Activity Contact for that activity immediately.
What Will Happen?
You will not be able to participate as a reviewer of the book. This prohibition
will not affect your selection to participate in future activities.
What Do I Need To Know About Confidentiality?
Definition: Confidential Information
CARRA activities involve both public and confidential information. While public
information can be shared with anyone, confidential information must be treated
carefully.
Confidential information cannot be shared with anyone other than
the NCI staff directly involved in that activity.
Confidential information includes any
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Information submitted to NCI for review, such as
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Grant applications
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Contract proposals
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Renewal/status reports
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Financial, professional, or personal information related to an individual or
organization, such as
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Salaries
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Performance reports
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Health information
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Recommendations or discussions related to funding decisions by NCI
Confidentiality Guidelines
It is your responsibility to comply with all restrictions regarding confidential
information. You must ask your Activity Contact to specify the confidential
information of each activity. Do not hesitate to ask any questions about
confidentiality.
How Confidentiality Is Unknowingly Violated
Confidentiality is often unknowingly violated when individuals seek assistance
in understanding technical or scientific issues. Do not consult anyone outside
the immediate project for technical assistance. You should contact NCI staff or
your mentor for assistance.
Consequences of a Breach in Confidentiality
Depending on the nature of the breach, you could
If you think that you have breached confidentiality, alert your Activity Contact
immediately.
What Do I Need To Know About Lobbying During CARRA
Activities?
Definition: Lobbying
Lobbying - any activity intended to influence public officials concerning
legislative or other policy decisions - is prohibited during any CARRA
activity, including both local meetings, and travel events.
The prohibition of lobbying includes the full time frame of the activity, from
the moment the activity starts until it is officially adjourned.
This prohibition means that CARRA members should not attempt to further their
own agendas while participating in CARRA activities. It also means that they
are NOT representing NCI when involved in lobbying activities.
The following are two examples of lobbying:
Example: Prohibited Situation
You are on a 2 day site visit to a cancer center in your State's capital. The
first night of the site visit, you have the opportunity to have dinner with
several members of your constituency and one of the senators from your state.
Is This Permitted?
No, you are not permitted to attend this dinner.
Why Not?
Your CARRA activity is still ongoing. You would be permitted to meet with your
senator the following afternoon, after the CARRA activity has adjourned.
Example: Permitted Situation
You are in the Washington, DC, area for a CARRA activity. The activity ends at
noon. You arranged your travel so that your flight does not leave until 8:00
p.m. that evening, enabling you to attend a lobbying day sponsored by your
advocacy group.
Is This Permitted?
Yes, you are permitted to attend the lobbying day activities.
Why?
Your CARRA activity adjourns before your participation in the lobbying activity
begins.
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