Administrators and the Responsible Conduct of Research
Tutorial:
Ownership of Data
Federal Policies

Ownership of Data – Institutional Policies

Institutional policies on data management and retention should address a number of key issues. The purpose of the policy is to guide members of the institution’s community on the rights and responsibilities of those involved, directly or indirectly, in the conduct of sponsored projects with regard to the need for appropriate stewardship Stewardship
The conducting, supervising, or managing of something; especially: the careful and responsible management of something entrusted to one's care. (Source: Merriam-Webster's 11th Collegiate Dictionary)
of data and information generated and accrued in the conduct of sponsored projects.

The focus of most institutional policies is on access to and retention of data, rather than ownership. The primary concern in sponsored project agreements is the right of access and the responsibility for retaining data for specified periods. On the other hand, most educational institutions intellectual property policies grant ownership of copyrightable materials to the creators. Thus, focusing on the access to and retention of data satisfies the institution’s responsibilities without over-complicating matters by introducing the concept of ownership.

Institutional policies must address access to and retention of original, primary and raw data, including recordings of such data. The rights of the federal government under sponsored agreements would not be satisfied by providing only summaries of data. In addition, in the case of legal disputes, having access to the original data may be required. There are, of course, certain exceptions to having to provide original or raw data if legitimate concerns for confidentiality are present. An example of this would likely be personally-identifying information of human research participants.

Most institutional policies regard the principal investigator as the "gatekeeper" to the data. That is to say, that since the principal investigator is the person responsible for collecting and generating the data in his/her research project, it makes sense that he/she would have the responsibility for stewardship of the data. This does not connote a transfer of ownership, but rather is an indication that the institution regards the researcher as the proper steward of research data.

Institutional Policies continues –>

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