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University Policies

Research Data Ownership and Retention

Policy Purpose

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This policy ensures that research data are retained and available for review by the University, sponsors and state and federal agencies.


Policy Statement

The University claims ownership of research data for projects conducted at the University, under the auspices of the University or using University resources by faculty, staff, students, post-doctoral fellows, scholars, and visiting scientists in the course of their scholarly activities. Both researchers and the University have rights and responsibilities for retaining research data.

This policy provides the requirements for the retention of data and data access as well as the transfer of data when an investigator leaves the University.


Policies from federal sponsors including the National Institutes of Health and National Science Foundation regarding data management, retention and sharing, and as directed in the Office of Science Technology Policy Memorandum, Increasing Access to the Results of Federally Funded Scientific Research (February 22, 2013).


Research Data
all recorded information in any form (e.g. laboratory notebooks; electronic data collected using laboratory instrumentation; computer software; videos; memoranda; research resources, including synthetic compounds, cell lines, microorganisms (bacteria and viruses) cloned nucleic acids, DNA sequences, plants and animals (e.g. knockout mice). For clinical studies, research data includes case histories, clinical protocols, case report forms and supporting documentation.

Principal Investigator (PI)
researcher with the primary responsibility of retaining research data and following the data management requirements of the University and the sponsor.

Research/Scholarly Activity
systematic investigation with the purpose of developing or contributing to knowledge.

Policy History

 Effective Date:   January 22, 2019

  1. University Responsibilities
    A. Comply with all federal and state regulations  governing data retention and access.
    B. Comply with the terms of all sponsored project grants and contracts.
    C. Maintain confidentiality of research data, where appropriate (e.g., HIPAA data, etc.)

  2. Principal Investigators Responsibilities
    The PI, as the custodian of the data, has primary responsibility for overseeing the conduct of research/scholarly activity, both extramurally funded and other, and is responsible for the retention of all data and records, providing access to the University, sponsors and regulatory agencies, and sharing data as required by the sponsor.

  3. Data Retention
    A. Research data must be retained a minimum of three years after the financial report for the project period has been submitted.
    B. Research data must be retained as long as required to protect any intellectual property that was produced as a result of the research.
    C. Research data involving human subjects must be maintained as required by the University’s Human Research Subjects Protection Program according to federal regulations (e.g. OHRP and FDA)
    D. Research data must be retained, when students were involved in the research/scholarly activity, must until the student’s degree is awarded, the student leaves the University or the research is published.
    E. Research data must be retained in the department or unit where it was generated.
    F. Following the conclusion of the period of retention, the PI may destroy the data in accordance with applicable federal regulations or sponsor requirements.

  4. Transfer of Responsibility When a Researcher Leaves the University
    If a researcher, other than the PI, departs the University, she/he may retain copies of all research data, but the original data must remain with the PI. If the PI leaves the University, the original data may be transferred to the new institution on approval by the University’s Vice Provost for Research and Sponsored Programs and a formal agreement that the new institution accepts responsibility for retaining the data, maintaining appropriate confidentiality and providing University access in order to fulfill its responsibilities under the terms of award, including allegations of research misconduct.
Procedure History

Effective Date:  January 22, 2019

Related Form(s)


Scope and Applicability




Responsible Official Responsible Office

 Vice Provost for Research and Sponsored Programs

Office of Research and Sponsored Programs




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