This article is part of the Iris Ethics Knowledge Base; you can find a directory of all articles here.
What is a public submission process?
A public submission process invites interested parties, usually in writing, to respond to a defined set of questions or issues raised by a government department, parliamentary committee, or independent review body. Submissions may come from organisations, advocacy bodies, professional associations, businesses, or individuals, and participation is open: the submitter chooses to take part, typically without direct interaction with the body receiving submissions. For evaluators and researchers in policy and program evaluation, social research, or market research, these processes can be a useful and legitimate source of data.
Does it require ethics review?
This depends on what is being done with the material and how the project is structured. Analysing submissions that are already on the public record may fall within the National Statement's exclusion for research using public data, information that has been published or has entered the public domain with the consent of the person(s) concerned, which does not, as an independent activity, require ethics review (NS, Purpose, Scope and Limits of this Document). See What counts as research for the general boundary between excluded activities and human research.
However, in many real-world projects, analysis of submissions is one component of a broader methodology that involves participants in other ways, in which case the project as a whole will generally require review. Evaluators or researchers who are themselves running a submission process as a data collection method are in a different position again: this is active engagement with participants and should be held to the same ethical standards as any other data collection method.
Why submission processes need active management
Many submission processes are lower risk: a planning authority inviting comment on a rezoning proposal will usually attract responses from organised stakeholders with relevant expertise. But some processes involve truly sensitive policy areas, such as child safety, family violence, mental health services, or disability support, and can attract submissions from individuals with direct lived experience of the issue, who may be disclosing information about themselves or others without any gatekeeping or structured support.
The core challenge is that submission processes are less controllable than most other methods. An interview or focus group allows the researcher to manage the environment, the consent process, and any participant distress in real time. A public submission process does not allow most of this: the evaluator or researcher cannot control who responds, what they disclose, or how prepared they are for the emotional weight of a written account. This means the ethical work needs to happen at the design stage, before submissions are received.
Autonomy and informed participation
The National Statement's guiding principle for consent is that a person's decision to participate is voluntary and based on sufficient information and adequate understanding of the research and the implications of participation (NS 2.2.1). A person who chooses to make a submission to a sensitive policy inquiry has exercised a form of autonomous decision-making; the fact that participation may be emotionally difficult, or that disclosure carries some risk, does not in itself make it ethically impermissible. What it requires is that the person has been given the information needed to understand what they are agreeing to, including how their submission may be used, stored, and potentially published.
Good practice for submission processes
- Be explicit in guidance materials about what kinds of information are relevant, and note that personal disclosures are not required to make a useful contribution.
- Explain clearly how submissions will be used, stored, and published, including whether they may appear on a public register.
- Offer anonymity or de-identification pathways where possible, designed in from the start rather than handled case-by-case.
- Remind submitters to consider whether they have the consent of any third parties, such as family members or service users, whose information they include.
- Build in an explicit acknowledgement or consent step where the channel allows it, such as a checkbox on an online form.
- Decide in advance how distressing disclosures, or disclosures that may trigger mandatory reporting obligations, will be handled, and document this in the project design.
Not all of these measures will be available in every context; submissions received by email, post, or phone limit the scope for structured consent steps, which is why the accompanying information provided to prospective submitters carries more of the ethical weight in those cases.
Related resources
- What counts as research: the exclusion for research using public data and where its limits lie
- General consent requirements: the information and consent principles that apply to submission processes run as data collection
- Children and young people (NS 4.3): capacity and maturity considerations where young people make submissions
This page was last updated on 16 September 2026.
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This article makes reference to the National Statement on Ethical Conduct in Human Research 2025. It is intended as practical guidance and does not constitute legal advice.
AI Disclosure: Resources in this library 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.