Ownership of Data – Institutional Policies (cont.)
Institutional policies must make some reference to compliance with the length of retention requirements. Given that sponsors have varying requirements for how long data must be retained, most policies will state that the institution will abide by the particular requirements stated in sponsor policies. Those individuals involved in data management, however, cannot rely solely on the basic sponsored project retention requirements since sometimes special policies will apply. For instance, if an invention is patented, technical data supporting the invention should be maintained for the life of the patent (i.e., twenty years).
The institution also needs to be concerned with the possibility of the principal investigator leaving the institution and what happens to the data. It is important for the institution to satisfy its compliance responsibilities while according to the individual all the normal rights of scholarship. There are two basic options for institutional policies. Either the researcher may take a copy of the data to his/her new institution and leave the original data, or the researcher may take the original data and leave a complete copy that is identical to the original. In the latter case, though not necessarily the preferred option, at the very least there needs to be a written agreement that the researcher will retain the original data for the required retention period and will permit authorized individuals to have access to that data.
The storage of data for the required period(s) of time should be a part of institutional policies. The policy should address whether centralized storage is required or an option that can be chosen by the principal investigator acting as steward of the data. Many investigators wish to maintain local control over their research data. This is certainly more feasible than was the case in the past given the relative ease of storing data in digital rather than paper form. The policy should also address the cost of data storage during the retention period and state who will be responsible for covering those costs under certain conditions.
The policy should also address the cost of data storage during the retention period and state who will be responsible for covering those costs under certain conditions. Institutional policies should address what data can and should be destroyed and when. Obviously, this is linked to the retention and cost requirements, but each institution needs to decide for itself whether it will keep data for the minimum period of time and who will have the responsibility to decide what data will be destroyed and what data may be retained for a longer period.
