Some Friendly Advice for Responding to Requests for Information About Animal Research
Requests made of a university, and individual researcher, or an Institutional Animal Care and Use Committee (IACUC) for information and records pertaining to animal research have become more and more common. This document suggests approaches for handling such requests; however, it is not intended to replace obtaining legal or otherwise appropriate advice for dealing with specific situations.
You can take steps in anticipation of a request for information or records about animal research programs at your institution. You should be aware of some of the possibilities for public disclosure as you engage in the research process. Consultation with the university administration, legal counsel, and IACUC can provide useful background information.
By taking some preliminary steps to become informed about applicable state and federal laws and institutional policies and by consulting with university administration, you can be prepared for requests for animal-research-related records. It may also be wise to proceed as if all records, correspondence, and research protocols are available for public scrutiny.
Learn about the Law
The level of public access to institutional records is largely determined by individual state laws. Federal statutes may also apply. It is useful to learn both state and federal laws and when they might apply. The application of particular laws may also depend on the status of the institution--public or private university--and the type of information being requested.
Two key features of many state laws that may warrant special attention are the definitions and exemptions. The definitions may establish what parts or bodies of the institution fall under the legislation and what type of information is considered public (e.g., faculty meetings, IACUC meetings, and minutes). These definitions may be very specific, identifying the appropriate institutional entities by name, or they may be more general. Exemptions may specify what types of information or activities are not covered under the law (e.g., not subject to public disclosure). Your institution's legal counsel should be consulted regarding the applicability of specific laws to your institution and research projects.
Know--or Help to Establish--Your Institutional Policy
Keep Your Institution Informed
Respond to a Request
Do you have the requested information? Do the requested records exist, and, if so, where? Some records may be in your possession, others may be in the university's possession, and yet others may be elsewhere, for example, they may be housed at your funding agency.
Are you required to obtain the records? If neither you nor your university has the records, you may need to determine whether you are obligated to obtain them. This is an area where laws may vary, so be certain of the obligations in your particular case.
Are there any restrictions on the requested information? Are all or some of the information or records protected from disclosure, that is, would disclosure violate any obligations concerning confidentiality?
Are you entitled to compensation for time and materials? Who is required to bear the financial costs of obtaining, copying, and sending the requested information?