Manuel B. Garcia

Manuel B. Garcia serves as the Senior Director for Educational Technology and Digital Learning at FEU Institute of Technology, Manila, Philippines. Read More

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What Should You Do When Two Institutions Give You Conflicting Research Requirements?

When two institutions give different research requirements, do not simply choose the easier rule or assume the lead institution automatically prevails. Identify what each requirement governs, where its authority comes from, and whether the requirements can be satisfied together before treating them as a true conflict.

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Conflicting Institutional Requirements Guide 98 of 398
01 · The Question

What Happens When Two Institutions Tell You to Do Different Things?

Your university requires research data to be retained for a particular period. A collaborating institution specifies another. One institution accepts a centralized ethics review, while another asks for additional local documentation. Your home institution permits a particular data-transfer method, but the host site does not.

Which institution's rule should you follow?

There is no universal rule that the home institution, host institution, lead institution, or institution with the stricter requirement automatically wins. The first task is to determine whether the requirements genuinely conflict. If they do, you need to establish what each requirement governs, where its authority comes from, and which organizations have authority over the activity in question.

02 · The Short Answer

Do Not Choose Between Requirements Until You Understand Their Authority

In Brief

When two institutions impose apparently conflicting research requirements, first identify the source, scope, and authority of each requirement and determine whether both can be satisfied. If they genuinely cannot, the responsible institutions should resolve the conflict before the affected research activity proceeds.

The stricter rule does not automatically prevail, nor does the lead institution automatically override the other. Some requirements apply only within one institution's authority, while others arise from law, regulation, ethics approval, sponsorship, contracts, or shared governance arrangements that neither institution can simply disregard.

03 · What You Need to Know

Different Requirements Are Not Always Conflicting Requirements

Start by writing down exactly what each institution requires

Researchers sometimes encounter what appears to be a conflict because two institutions use different terminology, forms, workflows, or administrative processes.

Institution A might say that data must be stored on an "approved institutional platform." Institution B might say that identifiable data cannot be transferred outside its secure environment. Those requirements are different, but they are not necessarily contradictory. A research arrangement might satisfy both by keeping identifiable data at Institution B and transferring only appropriately de-identified information to Institution A.

Before escalating a conflict, convert each instruction into a precise requirement: who must do what, to which activity or information, at what stage, and under what authority?

A genuine conflict exists when complying with one requirement would breach another

Two requirements become genuinely incompatible when you cannot satisfy one without violating the other.

For example, imagine one institution requires identifiable interview recordings to be transferred to the lead university, while the host institution's binding data agreement prohibits identifiable recordings from leaving its secure system. If neither requirement can be modified, the project has a genuine governance conflict.

By contrast, if one institution requires five years of record retention and another requires a minimum of three years, retaining the records for five years may satisfy both, provided no other requirement imposes a maximum retention period or requires earlier destruction.

Different requirements The institutions ask for different things, but both requirements can still be satisfied.
Conflicting requirements Compliance with one requirement would make compliance with the other impossible or impermissible.

Identify where each requirement comes from

Not every institutional instruction has the same source or force.

A requirement may arise from legislation, regulation, an ethics decision, institutional policy, sponsorship arrangements, a research contract, funding conditions, a data-sharing agreement, professional standards, site authorization, or an administrative preference.

This distinction matters. A department's preferred template may be negotiable. A legal prohibition may not be. A contractual term may require amendment. An ethics condition may need review by the ethics committee before the research team can change the approved procedure.

The current UK Policy Framework for Health and Social Care Research illustrates this layered structure. It expressly operates alongside legislation and other standards and assigns different responsibilities to investigators, sponsors, funders, research sites, employers, regulators, and care providers rather than treating one organization as universally controlling every research decision.

Ask what each institution actually has authority over

An institution can legitimately impose requirements within areas for which it has responsibility. That authority is not necessarily unlimited.

Your home university may govern your employment, research-integrity obligations, institutional data systems, and sponsorship arrangements. A hospital hosting the research may control access to its premises, clinical records, staff, information systems, and local resources. A collaborating laboratory may control its facilities and safety requirements.

This is why responsibility for research conducted outside your own institution should be mapped rather than assigned entirely to either the home or host organization.

When several institutions are involved, the relevant question is not simply, "Which institution is senior?" It is, "Which institution has legitimate responsibility for this particular activity?"

The lead institution does not automatically override participating institutions

Calling one organization the lead institution can clarify coordination, but it does not necessarily give that institution authority over everything another organization controls.

A lead university cannot ordinarily authorize access to another hospital's confidential records merely by declaring that the study has institutional approval. Likewise, a participating hospital cannot necessarily change a project-wide protocol on behalf of the sponsor and all other sites.

As the UK Policy Framework emphasizes, responsibilities should be clearly designated, communication pathways should be explicit, and research sites retain responsibilities for activities occurring through their sites.

The broader governance principle is that several institutions can share responsibility without having identical authority.

The stricter requirement does not automatically win

"Follow whichever rule is stricter" sounds safe, but it is not a universal conflict-resolution principle.

Sometimes satisfying the more demanding requirement does satisfy both. If one institution requires stronger encryption than another, using the stronger permitted standard may solve the problem.

But stricter is not always compatible. One institution might require data to be retained while another valid requirement requires destruction. One may require disclosure that another prohibits. One may require a procedure that falls outside the ethically approved protocol.

Severity therefore cannot substitute for authority analysis.

Do not solve ethics-related conflicts by changing the protocol informally

If resolving an institutional disagreement requires changing the approved research design, recruitment, consent process, participant information, data handling, intervention, or another ethically relevant aspect of the study, the change may require ethics review or another formal modification before implementation.

The UK Policy Framework specifically states that changes to research proposals or protocols should be submitted to research ethics committees and other relevant approval bodies when review is expected or required, and approved changes should then be introduced consistently across relevant sites.

A compromise between administrators therefore does not automatically amend an ethics-approved protocol.

Contracts and collaboration agreements should help prevent conflicts

Multi-institution research works more smoothly when responsibilities are allocated before data collection begins.

Agreements can identify which institution is responsible for ethics submissions, data storage, security, access, intellectual property, financial management, participant complaints, reporting, publication, research-integrity concerns, and other relevant functions.

This does not guarantee that disagreements will never occur. It does give the institutions an agreed starting point for resolving them.

Where responsibilities have never been documented, apparent policy conflicts can expose a more fundamental governance problem: nobody established which institution had authority over the issue in the first place.

Escalate the issue through the responsible governance channels

Researchers should not be left to privately adjudicate genuine institutional conflicts that exceed their authority.

Depending on the issue, resolution may require the principal investigator, research governance office, sponsor, institutional legal counsel, privacy or data-protection office, research-integrity office, ethics committee, contract manager, funder, or another responsible body.

The escalation pathway should match the issue. A data-sharing conflict belongs with the people responsible for data governance and the relevant agreement. An ethics condition belongs with the ethics process. A site-access dispute belongs with the institution controlling the site.

Document the resolution

Once the institutions agree on a solution, document it appropriately.

This may require an amended agreement, revised protocol, ethics modification, updated data-management plan, revised site authorization, written institutional clarification, or another formal record.

An email saying "we discussed this and it should be fine" may be sufficient for a minor administrative clarification. It is a poor substitute for formal amendment when the underlying governance document itself needs to change.

Watch Out

Do not quietly follow whichever institution gives you the answer you prefer. If two legitimate requirements cannot both be satisfied, proceeding under one while ignoring the other can turn an administrative disagreement into research non-compliance.

04 · A Practical Example

When Two Data-Retention Requirements Appear to Conflict

Hypothetical Example

A collaborative interview study

University A leads a study conducted with Hospital B. University A's policy requires the research record to be retained for at least five years. Hospital B tells the research team that identifiable recordings obtained through the hospital must be destroyed after two years under the project's local data arrangement.

Clarify the requirements The team determines that University A's five-year requirement applies to the research record generally, while Hospital B's two-year requirement specifically applies to identifiable audio recordings.
Check whether a conflict actually exists The team establishes whether University A requires the original recordings themselves to be retained or whether appropriately de-identified transcripts and other research records satisfy its retention requirement.
Consult the responsible offices The PI brings the issue to the institutions' research-governance and data-responsibility contacts rather than choosing a retention period independently.
Agree on the compliant arrangement If permitted by both institutions and the approved protocol, identifiable recordings are destroyed at the required point while permitted research records are retained for the longer period.
Update documentation if necessary If the resolution changes the approved data-management plan or contractual arrangements, the appropriate documents and approvals are amended before the change is implemented.

What initially looked like a five-year-versus-two-year conflict may turn out to concern different records. Clarification should come before escalation, and escalation should come before unilateral non-compliance.

05 · What Researchers Often Get Wrong

Common Mistakes When Institutional Requirements Differ

Misconception

The Lead Institution's Policy Always Wins

Not necessarily. A lead institution may coordinate the project without having authority over another organization's premises, records, systems, employees, or legal obligations. Authority should be established issue by issue.

Misconception

You Should Always Follow the Stricter Requirement

Sometimes the stricter requirement satisfies both institutions, but not always. A requirement can be more restrictive while still conflicting with another binding obligation. Determine compatibility and authority rather than using strictness as the sole criterion.

Misconception

Different Forms or Procedures Mean the Institutions Disagree

Not necessarily. Institutions can implement compatible requirements through different administrative processes. Focus on the substantive obligation before declaring a governance conflict.

Misconception

The PI Should Decide Which Rule Makes More Sense

The PI should identify and escalate conflicts, but may not have authority to waive institutional, contractual, legal, or ethics requirements. Genuine conflicts should be resolved by the responsible bodies.

Misconception

If Both Institutions Approved the Study, Future Conflicts Cannot Occur

Requirements can change during research, and new amendments, data arrangements, personnel, sites, laws, or institutional policies can create issues that were not present at initial approval. Governance therefore continues throughout the project.

06 · What This Means for You

Resolve the Authority Before Resolving the Requirement

When institutions disagree, use a structured process rather than informal negotiation alone.

A simple conflict-resolution framework

If the requirements are worded differently
Translate each into a precise substantive obligation and determine whether both can be satisfied.
If both requirements can be satisfied
Design the research process to satisfy both and document the arrangement where necessary.
If the requirements genuinely conflict
Identify the source and authority of each requirement and escalate the conflict to the responsible institutional bodies.
If resolving the conflict changes the approved protocol
Determine whether an ethics amendment, sponsor approval, site modification, or other formal review is required before implementing the change.
If one requirement arises from a collaboration agreement
Review the agreement's allocation of responsibilities and amendment or dispute-resolution process rather than ignoring the provision.
If the conflict cannot be resolved before the affected activity
Do not proceed with that activity until an authorized and compliant pathway has been established.

When the disagreement extends beyond institutional policies to funder, legal, or ethics requirements, the issue becomes a broader conflict among different sources of research authority.

07 · A Quick Checklist

Before Deciding That Two Institutional Rules Conflict

Work through the requirements:
Have you written each requirement precisely rather than relying on verbal summaries?
Do the requirements apply to the same activity, information, person, or stage of the research?
Can both requirements be satisfied simultaneously?
What is the source of each requirement: law, regulation, ethics decision, policy, contract, sponsorship, funding condition, or administrative procedure?
Which institution or body has legitimate authority over the activity in question?
Does an existing collaboration, data-sharing, sponsorship, or site agreement allocate responsibility for the issue?
Have the appropriate governance offices or responsible decision-makers discussed the conflict directly?
Would the proposed resolution require an ethics amendment or another formal approval?
Has the final resolution been documented in the appropriate governance records?
08 · Frequently Asked Questions

Questions About Conflicting Institutional Requirements

Should I always follow the stricter institution's rule?

No universal rule says that the stricter institutional requirement automatically prevails. If the stricter requirement satisfies both, it may provide a practical solution. If requirements are genuinely incompatible, their authority and source need to be resolved rather than ranked merely by strictness.

Does my home institution's policy override the host institution?

Not automatically. The home and host institutions can have authority over different aspects of the research. Determine what each requirement governs and whether both apply to the activity.

Can my PI choose which institution's requirement to follow?

The PI can help interpret and escalate the issue but may not have authority to waive requirements belonging to another institution, sponsor, ethics body, regulator, or contractual arrangement. Genuine conflicts should be resolved through the appropriate governance channels.

What if one institution changes its policy after the study starts?

Determine whether the new policy applies to ongoing research and whether compliance requires changes to the protocol, agreements, approvals, or data arrangements. Do not assume either that existing studies are exempt or that the new policy automatically changes an approved protocol.

What if the institutions cannot agree?

If the disagreement concerns a requirement that must be resolved before a particular research activity, that activity should not proceed until a compliant arrangement is established. The institutions may need to amend the collaboration, alter site participation, modify the protocol, or reconsider whether the activity can be conducted as planned.

Can an ethics committee resolve a conflict between two institutional policies?

Only within its remit. An ethics committee can address ethical implications and determine whether proposed protocol changes remain ethically acceptable, but it may not have authority to resolve contractual, employment, legal, financial, or institutional-policy disputes.

09 · The Bottom Line

Do Not Choose a Rule Until You Know What Gives It Authority

The Bottom Line

When two institutions give apparently conflicting research requirements, determine whether the requirements genuinely conflict, identify the source and scope of each one, and establish which institution has authority over the activity before deciding how the conflict should be resolved.

Many apparent conflicts can be reconciled. Genuine conflicts require authorized institutional resolution and sometimes amendments to protocols, agreements, or approvals. The research team should not solve them by quietly following whichever requirement is easier.

10 · Sources and Further Reading

Authoritative Guidance on Multi-Institution Research Governance

11 · Cite this Guide

How to Cite This Guide

This guide is intended to be read, shared, and used in research, teaching, and academic work. If you draw on its ideas, explanations, or other content, please acknowledge the source by citing the guide. Doing so gives appropriate credit and helps your readers locate the original resource.

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