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datamanagement

Responsible Conduct of Research

Data Acquisition, Management, Sharing and Ownership

Federal Regulations

UVM Guidelines

Data Management - Privacy and the integrity of research have implications for the storage and retrieval of data.  For specific information, please see UVM's Policy on Access to and Retention of Data below.

Investigators should also refer to UVM's intellectual property policy for guidance on the disposition of data when they leave UVM.

Researchers spend much of their time collecting data. Data are used to confirm or reject hypotheses, to identify new areas of investigation, to guide the development of new investigative techniques, and more. We launch space probes to collect data that help us understand the origins of the universe and use gene databases as tools for understanding and curing disease. Science as we know and practice it today cannot exist without data.

Data management practices are becoming increasingly complex and should be addressed before any data are collected by taking into consideration four important issues:

  1. ownership
  2. collection
  3. storage
  4. sharing

The integrity of data and, by implication, the usefulness of the research it supports, depends on careful attention to detail, from initial planning through final publication.

UVM Policy on Access to and Retention of Data

Summary

This policy specifies individual and institutional rights and responsibilities concerning the access to and retention of data developed and/or used in the conduct of externally sponsored research and scholarly activity while an individual is employed by the University. It covers the rights and responsibilities of individual members of the University community, the University, and those external to the University who may have rights of access to the data.  This policy has been developed by the Committee in response to Federal regulation regarding the status and disposition of data developed under Federal sponsorship, and brings UVM into compliance with those regulation.

Background

Data are created at the University of Vermont by faculty, staff, and students in the course of their scholarly activities and often while conducting projects funded by external sponsors.  By tradition and for practical reasons, the creators of data retain control of, access to, and use of data even though the University, through the requirements of external sponsors, may be required to hold title to the data. Because of the obligations accepted by the University in sponsored project agreements, the University recognizes that it has responsibilities with respect to access to and retention of data.

Recent clarifications of federal regulations regarding record retention, as well as Congressional attention to various issues concerning the government's support of research, including instances of scientific misconduct, have prompted the University to develop this policy for retention of and access to data.  Of particular concern are the requirements of Office of Management and Budget (OMB) Circular A-110 which specifies that financial records, supporting documents, statistical records, and all other records pertinent to an award shall be retained by the institution. OMB stated in a letter dated April 11, 1994 that the term "all other records pertinent to an award" encompasses all records that were produced in connection with the award, including laboratory data and primary data.

Policy

Definition of Data:  As used in this policy, data means recorded information, regardless of form or the media which records them. The term includes computer software (computer programs, computer databases, and documentation thereof), and data/information of a technical or scientific nature. It also includes information discovered or generated in the course of humanities and social science projects that may not fit the common perception of "scientific" data.  In practice, data include, but are not limited to, materials contained in laboratory or other notebooks or other media such as computer disks and machine printouts.  Data also include both intangible data (statistics, findings, observations, etc.) and tangible data (notebooks, printouts, etc.)

Policy: Data created while individuals are pursuing research studies as faculty, staff, or students of the University of Vermont and data created by visiting scientists using the facilities of the University of Vermont, will be retained by the University for a period of five (5) years after submission of the final report on the project for which the data were collected, unless a longer retention period is specified by the sponsor. Where no final report is required, the University shall retain the data for 3 years after its public release.

The original data shall be in the custody of the senior investigator on behalf of the University, and access must be allowed upon the request of the Provost or an individual designated by him/her. Additionally, at the direction of the Provost or his/her designee, data are to be made available to representatives of external funding sponsors or designated government officials, when such access is legally required or is appropriate to a given circumstance. Such data must not be destroyed or altered during the time period referenced above.

Investigator Responsibilities at the University:  Investigators are ultimately responsible for documenting the results of research and scholarly activity. Senior members of research groups have an obligation to discuss the responsibilities of data recording, management, and retention with others involved in the conduct of projects. As a matter of practice, original data should be left with the senior investigator when a student leaves the University, but copies of that data, where appropriate and feasible to do so, should be provided to the student.

Investigator Responsibilities After Leaving the University: When an investigator leaves the University, the University retains access to the data. It is neither feasible nor desirable for the original project records to remain at the University, but departing investigators should understand their obligation to hold these data in trust for the University and that such data must be made available to the University if requested during the three (3) year period after the submission of the final report of the project for which the data were developed or used, unless a longer period is specified by the external sponsor of the project.

Last modified July 05 2011 02:53 PM

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