Data Stewardship, Access, and Retention

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Policy Number:
UW-4032
Responsible Office:
Office of Research Policy and Integrity

University Policy

Rationale/​Purpose:

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.

Definitions:
Data
Recorded factual material, regardless of the form or media on which it may be recorded, that is commonly accepted in the research community as necessary to validate research findings. For example, data may include writings, films, sound recordings, pictorial reproductions, drawings, designs, or other graphic representations, procedural manuals, forms, diagrams, workflow charts, equipment descriptions, data files, statistical records, and other research data. This definition pertains to both primary and secondary data.
Primary data
Data generated by research conducted at the university, under the auspices of the university, or with university resources.
Secondary data
Data owned and or generated by another party; data collected from administrative records; or data designated for public use but used in whole or in part for research conducted at the university, under the auspices of the university, or with university resources. This definition of data excludes research results based on data such as preliminary analyses, drafts of research papers, published papers, plans for future research, peer reviews, or communications with colleagues. This definition does not supersede any campus policy pertaining to intellectual property.
Principal investigator (PI)
For purposes of this policy, means a researcher with primary responsibility for a research project, a definition that applies whether or not the research is sponsored by an external funding source. A principal investigator's responsibility includes both leadership of the scientific/technical aspects and compliance with administrative aspects of the research.
Others on campus, including certain academic staff titles, visiting scholars, postdoctoral fellows or other trainees, and graduate or undergraduate students, who would initiate a research project and are not themselves eligible to be a principal investigator, must identify a faculty member, academic staff person with permanent principal investigator status, or another authorized person to serve as principal investigator.
Other research contributors
Any persons other than the principal investigator who have made a substantial contribution to the conception and design of research, acquisition of data, or analysis and interpretation of data. Contributors may include faculty collaborators, academic staff, visiting scholars, postdoctoral fellows or other trainees, research technicians, and graduate or undergraduate students. In general, persons performing narrow technical or clerical tasks would not qualify as contributors.
Scope:

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.

Policy:

Policy

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.

Scope

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:

  1. Complying with the terms of sponsored project agreements.
  2. Ensuring the appropriate use of animals, human subjects, recombinant DNA, disease-causing agents, radioactive materials, and the like.
  3. Protecting the rights of students, postdoctoral scholars, and staff, including, but not limited to, their rights to access data from research in which they have participated.
  4. Facilitating the investigation of charges, such as scientific misconduct or conflict of interest.
  5. Supporting university personnel in securing and protecting intellectual property rights.

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.

Stewardship and Retention

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:

  1. Data must be kept for as long as may be necessary to protect any intellectual property resulting from the work.
  2. If any charges regarding the research arise, such as allegations of scientific misconduct or conflict of interest, data must be retained until such charges are fully resolved.
  3. If a postdoctoral scholar or another trainee, graduate student, or undergraduate student is a research contributor, data must be retained at least until the degree is awarded, training is completed, or it is clear that the individual has abandoned the work.

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.

Access

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.

Transfer in the Event a Researcher Leaves UW–Madison

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.

Roles and Responsibilities

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.

Interpretation of Policy

Questions on the interpretation of this policy may be directed to the vice chancellor for research and graduate education.

Related UW-Madison Policies:
Related UW–Madison Documents, Web Pages, or Other Resources:
External References:

Policy Administration

Approval Authority:
Vice Chancellor for Research
Policy Manager:
Vice Chancellor for Research
Contact:
Associate Vice Chancellor for Research Policy and Integrity -- Mark Rickenbach, MARK.RICKENBACH@WISC.EDU, (608) 890-0225
Effective Date:
12-16-2010
Retrieved:
10-05-2024 10:05:13