To ensure that UW–Madison research data are appropriately maintained, archived for a reasonable period of time, and available for review and use under the appropriate circumstances.
This policy applies to all UW–Madison faculty, academic staff, visiting scholars, postdoctoral fellows and other trainees, research technicians, graduate and undergraduate students, and any other persons at UW–Madison involved in the design, conduct, or reporting of research at or under the auspices of UW–Madison, and it applies to all research projects on which those individuals work, regardless of the source of funding for the project.
UW–Madison must retain research data in sufficient detail and for an adequate period of time to enable appropriate responses to questions about accuracy, authenticity, primacy, and compliance with laws and regulations governing the conduct of the research. It is the responsibility of the principal investigator to determine what needs to be retained under this policy.
The university's requirements for stewardship of the research record for projects conducted at the university, under the auspices of the university, or with university resources are based on regulation (2 C.F.R. 200, Subpart D, Record Retention and Access, §§ 200.334 – 200.338), UW System policy, and sound management principles. UW–Madison's responsibilities in this regard include, but are not limited to:
Where research is subject to an agreement with UW–Madison that includes specific provision(s) regarding retention of and access to data and other records of research conducted under the auspices of the UW–Madison, the provision(s) of that agreement will supersede this policy. However, UW System Administrative Policy 342, Extramural Support Administration Section V.B.(9) "Data" provides that "No agreement shall be entered into with any extramural sponsor which allows for the transfer of the ownership of data."
In the case where an outside party has provided a UW–Madison investigator with secondary data for the purposes of research, requirements to retain research data in sufficient detail and for an adequate period of time will apply to that portion of secondary data used in the research.
Principal Investigators should adopt an orderly system of data organization, access, and retention and should communicate the chosen system to all members of a research group and to the appropriate administrative personnel, where applicable. Particularly for long-term research projects, principal investigators should establish and maintain procedures for the protection of essential records in the event of a natural disaster or another emergency.
Research data must be archived for a minimum of seven years after the final project close-out, with original data retained wherever possible. Principles of good stewardship would justify longer periods of retention in the following cases:
Beyond the period of retention specified here, the disposal of the research record is at the discretion of the principal investigator and their department or work unit (e.g., laboratory). As a practical matter, data may be translated to more efficient storage media as long as the essential nature of the data is not lost. For example, lab notebooks may be scanned, audio recordings transcribed, questionnaires coded and digitized, and the like.
Records will normally be retained in the unit where they are produced. Research records must be retained on the UW–Madison campus, or in facilities under the auspices of UW–Madison, unless specific permission to do otherwise is granted by the vice chancellor for research.
As part of the stewardship of research data, the principal investigator will create explicit understandings with other research contributors regarding access to and use of data. These understandings ought to reflect access appropriate to one's role and contribution to the conception and design of research, acquisition of data, or analysis, and interpretation of data.
It will also be the responsibility of the principal investigator to follow the requirements of any sponsored agreements with regard to access to data.
Where necessary to ensure needed and appropriate access, the principal investigator, upon request of the university, must provide the university with research data. Under extraordinary circumstances, such as research misconduct, the university will take all necessary steps to ensure the integrity of the data in a manner specified by the UW Policy for Misconduct in Scholarly Research (FP&P II-314).
None of these provisions is intended to supersede the principal investigator's right to keep data proprietary until the results of the research have been published and the aims of the research have been fulfilled.
When individuals involved in research projects at UW–Madison leave the university or move to a different research group or position at UW–Madison, they may, with principal investigator approval, take copies of research data that they have generated or to which they have made a substantial contribution for projects on which they have worked. Original data, however, must be retained at UW–Madison by the principal investigator.
If a principal investigator leaves UW–Madison, and a project is to be moved to another institution, the data may be transferred with the approval of the vice chancellor for research, and with written agreement from the principal investigator's new institution that guarantees: 1) its acceptance of custodial responsibilities for the data, and 2) UW–Madison access to the data, should that become necessary.
Data sets comprised of directly or indirectly identifiable human subjects data may not be transferred outside of the university without UW Institutional Review Board (IRB) review and approval of the transfer. IRB review and approval to use the data may also be needed from the institution to which the data will be transferred.
The principal investigator is responsible for the stewardship and retention of research data as well as for determinations concerning access to and appropriate use of data.
Other research contributors are responsible to cooperate with the principal investigator in carrying out the requirements of this policy.
The dean(s) of the school(s)/college(s) in which the principal investigator is appointed may hear appeals concerning issues of access to data and determine who shall have access.
The vice chancellor for research may hear appeals to a dean's determination concerning access to data and make a final determination. The vice chancellor for research may determine, consistent with campus policy, who is eligible to serve as a principal investigator.
Questions on the interpretation of this policy may be directed to the vice chancellor for research and graduate education.