University-based research, including federally funded research, must satisfy an ethics review when it is first formally proposed. Such an ethics review includes an assessment of the legality of the proposed research methodology. If the work fails the review, there will be no grant funding and the research will never begin; in the instance of periodic ethics reviews during an extended research project, the research will stop. Without such exceptions to Bill C-32’s anti- circumvention provisions as those outlined above, the research would be illegal and thereby stultified. Accordingly, we feel there must be a general research exception to Bill C-32’s anti- circumvention provisions if Canada’s university-based researchers are to be able to continue their work.
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