Introduction

The 2025 National Statement provides guidance on disseminating research outputs and outcomes in Element 6 of Chapter 3.1 (paragraphs 3.1.68–3.1.71). Whilst the Statement emphasises public dissemination as an ethical principle, it also recognises that legitimate reasons exist to restrict or delay sharing findings. For practitioners in evaluation, social research, and market research, this creates a tension: how do we balance ethical obligations to participants and the broader community with the commercial and confidential nature of much of our work?

The National Statement also provides guidance on communicating findings to participants at Element 5 of Chapter 3.1 (paragraphs 3.1.62-3.1.64). This special case of findings dissemination raises different considerations for practitioners, so we will cover it in more depth in a future resource.

The National Statement's Position: Public Good as Default

The National Statement is explicit: making research outputs publicly available is consistent with the principles of respect, beneficence, and justice. It's also a requirement for research merit and integrity. The underlying logic is straightforward. Research that contributes to knowledge or practice serves a public good, and that contribution is realised through dissemination.

Common dissemination mechanisms include peer-reviewed publications, conference presentations, commissioned reports for public bodies, and creative outputs. The form matters less than the function, that is, ensuring that the knowledge generated benefits others beyond the immediate research team and commissioning organisation.

Importantly, paragraph 3.1.68 requires researchers to advise ethics reviewers about:

• Plans to disseminate outputs widely to contribute to knowledge or practice
• Any risk factors or commercial interests that might legitimately restrict dissemination
• Whether the risks of dissemination are justified by the benefits (such as public interest)

Importantly, the National Statement does not prohibit restriction of findings. However, the rationale to do so must be justifiable in the context of the activities. 

Most Evaluation and Market Research Isn't Publicly Disseminated

Most evaluation and market research projects are commissioned for internal organisational use or commercial advantage. The client typically controls dissemination decisions. This creates several practical challenges. For example:

• Internal evaluation projects: An organisation commissioning an evaluation of its employee wellbeing program, service delivery model, or strategic initiative often does so to inform internal decision-making. Publishing findings externally may expose commercial sensitivities, competitive disadvantages, or reputational risks.
• Market research: A company researching consumer attitudes towards a new product line isn't doing so for the public good, but for competitive advantage. Participants generally understand this context, and disseminating findings publicly would undermine the commercial purpose of the research.
• Government and policy evaluation: Even publicly funded evaluations may be subject to cabinet-in-confidence provisions, political sensitivities, or policy development processes that require findings to remain internal until decisions are finalised.

In these contexts, public dissemination isn't merely restricted. It's often contractually prohibited or practically impossible.

Participant Expectations and Informed Consent

Here's where the National Statement's guidance becomes particularly relevant. If participants are sufficiently informed at the consent and recruitment stages that the research won't produce public outputs, then the ethical risks of non-disclosure are substantially mitigated.

This means your participant information sheets and consent processes need to be explicit:

• Who will receive the research findings (e.g., "only the commissioning organisation")
• Whether findings will be made public (e.g., "no public report will be produced")
• How participants' data will be used and by whom
• What outputs, if any, participants themselves will receive

Consider these scenarios, based on the earlier examples:

Scenario 1: Employee satisfaction survey 

A large healthcare organisation commissions an evaluation of staff wellbeing. Employees are told during recruitment that findings will be reported internally to senior management to inform workplace improvements, but no public report will be produced. Individual responses will be de-identified, and only aggregate data will be reported. Employees can still provide meaningful consent because they understand the purpose, audience, and use of their participation.

Scenario 2: Market research on brand perception 

A consumer goods company conducts focus groups to test messaging for a new product. Participants are explicitly told the research is for commercial purposes, findings will remain confidential to the company, and no public outputs will be produced. They're compensated for their time. The research purpose is transparent, and participants can make an informed decision about whether to participate on those terms.

Scenario 3: Program evaluation with sensitive findings 

A state government commissions an evaluation of a youth justice program. The terms of reference specify that the final report will be internal-only due to political sensitivities around potential negative findings. Participants (young people, their families, and service providers) are told that their input will inform program improvements but that the report won't be publicly released. This is ethically defensible if the restriction is justified by legitimate risks (e.g., re-identification of vulnerable participants, political interference with evidence-based policy development).

The key factor in each case is that participants know what they're consenting to, and the restriction on dissemination is clearly articulated upfront.

Reciprocity is an Ethical Obligation

Whilst the National Statement permits restricted dissemination under certain circumstances, it doesn't absolve researchers and evaluators of their obligations to participants. Paragraph 3.1.70 requires researchers to advise participants about "the format and medium or media that will be used to disseminate outputs or outcomes of research to them" and when this will occur. Paragraph 3.1.71 requires that any outputs disseminated to participants are "clear and understandable".

This is where reciprocity becomes essential. Even if your research won't be publicly disseminated, participants deserve something in return for their time, data, and trust. This is particularly critical when working with certain groups and communities:

• Aboriginal and Torres Strait Islander communities: Research and evaluation with Aboriginal and Torres Strait Islander peoples has a long history of extraction without benefit. The National Statement's Chapter 4.7, alongside the AIATSIS Code of Ethics, emphasises reciprocity, benefit-sharing, and community control over outputs. If your evaluation or research involves Aboriginal and Torres Strait Islander participants, restricted dissemination to a commissioning organisation alone in almost all cases is ethically insufficient. Communities must receive outputs that are meaningful and useful to them, and not just a perfunctory summary. 
• Culturally and racially marginalised groups: Groups that have historically been subject to exploitative research and evaluation practices deserve particular consideration. Disseminating findings in ways that benefit these communities, such as through accessible summaries, community presentations, or co-designed outputs, demonstrates respect and builds trust. 
• People with disability: Similarly, people with disability have often participated in research and evaluation that benefits researchers/evaluators or service systems without tangible benefit to participants themselves. Providing accessible research summaries or involving participants in shaping how findings are communicated is both ethically sound and practically valuable.

Practical examples of reciprocity include:

• Plain-language research summaries provided to all participants
• Community presentations or workshops to share findings and recommendations
• Co-designed outputs developed with participant representatives
• Feedback sessions where participants can respond to preliminary findings
• Accessible formats (Easy Read, audio, video) for diverse participant groups

These don't require public dissemination, but they do require intentional effort to ensure participants benefit from the activities they've contributed to.

Commercial Interests and Legitimate Restrictions

Paragraph 3.1.68(b) acknowledges that "risk factors or commercial interests" may legitimately restrict dissemination. The Statement doesn't define what "legitimate" means, but a reasonable interpretation includes:

• Commercial confidentiality: Market research commissioned to inform competitive strategy, product development, or business planning involves genuine commercial interests. Participants are typically aware of this context, and public dissemination would undermine the research purpose.
• Contractual obligations: Many evaluation and research contracts include confidentiality clauses. Researchers must honour these obligations, provided they were transparent with participants about dissemination restrictions during consent.
• Risk to participants: In some cases, public dissemination may pose risks to participants, for example re-identification, stigmatisation, or exposure of sensitive information. Restricting dissemination to protect participant welfare is not only legitimate but ethically required.

What's not legitimate? Withholding findings simply because they're negative, inconclusive, or politically inconvenient. If your client wants to suppress findings for reputational reasons alone, that's an ethical problem.

Transparency Is Non-Negotiable

When submitting your project for ethics review, you must be transparent about dissemination plans (or the lack thereof). Paragraph 3.1.68 requires researchers to advise reviewers about:

• Whether you intend to disseminate outputs widely
• Any restrictions on dissemination and their justification
• How you've weighed the risks and benefits of restricted dissemination

If your project is internal-only or commercially confidential, say so explicitly and explain why. If participants will receive summaries or other outputs, describe what these will look like and when they'll be provided. If it is unclear at this time whether publication will take place, then this needs to be stated. In such cases it is prudent to adopt the position that publication will not take place and to explain the legitimate justification as to why publication will not take place.

Our ethics committee and reviewers aren't there to block commercial or internal research and evaluation. They're there to ensure participants are treated ethically and that restrictions are justified. Transparency during review makes the approval process smoother and demonstrates your commitment to ethical practice.

Other Codes of Conduct Still Apply

Even if your research won't be publicly disseminated, Paragraph 3.1.69 requires adherence to "prevailing standards for ethical reporting, referencing and authorship". This means the Australian Code for the Responsible Conduct of Research and other codes such as those of the Australian Evaluation Society still apply to internal reports, client deliverables, and any other outputs. 

In practice this can look like:

• Properly attributing sources and collaborators
• Ensuring authorship reflects genuine intellectual contributions
• Reporting findings honestly and accurately, even if they're not what the client wants to hear
• Avoiding conflicts of interest or disclosing them transparently

Just because a report is internal doesn't mean you can cut corners on integrity.

Practical Steps for Practitioners

Here's how to navigate dissemination ethically in evaluation, social research, and market research:

1. Be explicit during recruitment and consent processes: Tell participants exactly who will see the findings and what (if anything) they'll receive in return. Don't leave room for misunderstanding.
2. Build reciprocity into project design: Plan participant-facing outputs from the start such as summaries, presentations, and feedback sessions. Don't treat this as an afterthought.
3. Negotiate dissemination terms with clients early: Clarify contractual restrictions before submitting for ethics review. If a client wants to suppress findings for illegitimate reasons, then there is an ethical obligation to educate clients on the requirements of the National Statement and related codes of conduct.
4. Justify restrictions to ethics reviewers: Be transparent about why dissemination is restricted and how you've balanced competing interests. Ethics committees are more likely to approve projects when the rationale is clear.
5. Prioritise vulnerable and marginalised groups: If your research involves Aboriginal and Torres Strait Islander communities, people with disability, or other marginalised groups, reciprocity is an essential component. 
6. Document your decisions: Keep records of dissemination discussions with clients, ethics committees, and participants. This protects you if questions arise later.

Final Thoughts

The National Statement's guidance on dissemination reflects an ideal: research and evaluation should contribute to public knowledge and practice. For many of us working in evaluation and market research, that ideal doesn't align with commercial and political realities. But that doesn't mean we abandon ethical principles. Instead it means we must navigate them thoughtfully.

Restricted dissemination is ethically defensible when participants are fully informed, restrictions are justified, and reciprocity is built into the research design. What's indefensible is treating participants as data sources without regard for what they receive in return, or withholding findings simply because they're inconvenient.

The tension between public good and confidentiality won't disappear. But by being transparent with participants, honest with ethics reviewers, and intentional about reciprocity, we can conduct evaluation and market research that's both commercially viable and ethically sound.

AI Disclosure:  Initial drafts of the content for this article were prepared using Large Language Models with input from Iris Ethics staff who guided the scope and design. Subsequent revisions and final versions were developed and approved by Iris Ethics staff.

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