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Division of Research Offices > Compliance and Committees > CPHS

Data Retention

Research data generated while individuals are pursuing research studies as faculty, staff, or students of the University of Houston, and data generated by visiting scientists utilizing the facilities of the University of Houston, are to be retained by the institution for a period of three (3) years after submission of the final report on the research project for which the data were collected, unless a longer retention period is specified by the sponsor.

The original research data may be retained by the senior investigator on behalf of the institution but must be returned to the institution upon request of an appropriate institutional official. Additionally, such data must be available to representatives of external sponsors of the research or designated governmental officials, when such access is appropriate. Such data must not be disposed of during the time period referenced above unless explicit written approval for such disposition is received from the Executive Vice President for Academic Affairs/Provost or a designee of such individual.

Information Related to Policy Statement

Definition
Research Data means recorded information, regardless of form or the media on which it may be recorded. The term includes computer software (computer programs, computer data bases, and documentation thereof), and data of a scientific or technical nature. The term does not include information incidental to award administration, such as financial, administrative, cost or pricing, or management information. In practice, scientific data include, but are not limited to, material contained in laboratory notebooks or other media such as computer disks and machine printouts. Data includes both intangible data (statistics, findings, conclusions, etc) and tangible data (notebooks, printouts, etc.).

Research Data is specifically limited to data generated under organized research funding (i.e., research activities which are separately budgeted and accounted for) and does not include departmental research (i.e., that not separately budgeted and accounted for).

OMB Circular A-110 ("Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations") specifies in section __.53(a) that financial records, supporting documents, statistical records, and all other records pertinent to an award shall be retained by the institution. In an April 11, 1994 letter, OMB has stated 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.

Discussion
The University of Houston recognizes that the generators of data (faculty, staff, students) often believe that they own the data produced in their laboratories and that they have an interest in ensuring that the data are used in an appropriate manner. At the same time, the University recognizes that it has legal responsibilities with regard to access and retention of data, particularly data generated under sponsored agreements.
It is important that investigators be able to document the results of research, both for the sake of meeting legal requirements as well as for the more traditional reasons of establishing priority for patentable items, publishing manuscripts, etc. Senior members of research teams have obligations to discuss the responsibilities of data management and retention with other members of a research team. As a matter of practice, original data should be left with the senior investigator when a student leaves the institution, but copies of that data, where feasible to do so, should be provided to the student.

When an investigator leaves the institution, (s)he must recognize that the institution must have access to the data. It is neither feasible nor desirable for the original research records to remain at the originating institution, but departing investigators must understand that they have an obligation to hold these data in trust for the institution and that such data must be returned to the institution if requested for a period of three (3) years after submission of the final report on the research project for which the data were collected, unless a longer retention period is specified by the sponsor.

Investigators should be cognizant of the requirement to retain research data, but should recognize that certain information may be generated (for example, instrument test runs, set-up runs, etc.) which is not research data and therefore need not be retained. Reliance should be placed on discipline-specific standards and expectations and the judgment of the senior members of the research team.


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Page last modified: 08/02/2012