I. Purpose  

Accurate and appropriate documentation of the results of research is an essential feature of any research project. The University of Iowa (UI) and its researchers share an interest in assuring that research data are accurately and appropriately recorded, used, retained, and available for review and sharing. In addition, increased mobility among academic researchers has resulted in the need to provide policies governing continued access to research data.   UI ownership and stewardship of research data are based on applicable laws and regulations, contractual agreements, UI policies, and sound management principles to ensure:  

  • alignment with the UI mission;  
  • the required preservation and accessibility of research data;  
  • the promotion of open science;
  • the commitment to providing benefit to the public;  
  • consideration for proprietary, confidential, and controlled information;
  • compliance with privacy laws and regulations; and • availability of data supporting research proposals and publications.  

II. Scope of policy  

This policy shall apply to all UI faculty, staff, students, and any other individuals involved in the design, conduct and reporting of research at or under the oversight of UI, and it shall apply to all research projects on which those individuals work, regardless of the type of research or the source of support for the project.     Oversight of policy. This is policy is overseen by the Vice President for Research.

 III. Definitions  

"Investigator" means a person, whether an employee or otherwise affiliated with UI, whose position responsibility statement, job description, employment assignment, and/or function within the UI is, either in whole or in part, to conduct Research, whether sponsored by external sources, internal sources, or unfunded. Such Investigators shall include, but not be limited to, faculty, staff, students, or others serving as members of a Research team.  

“Principal Investigator” or “PI” means an Investigator who has primary responsibility for a research project within the UI for the design, conduct, and reporting of Research.  

“Research” means a systematic investigation, including research development, testing, and evaluation, designed to develop or contribute to generalizable knowledge (basic research) or specific knowledge (applied research).  

“Research Data” means recorded information (in any media or format), factual material, and the associated processes (including protocols) that are commonly accepted in the scientific community as both necessary and sufficient to document and support research findings. Research Data Policy  Jan. 12, 2017; Rev.  April 14,2023 2   Examples of Research Data include, but are not limited to: documents, spreadsheets, databases, laboratory notebooks, field notebooks, diaries, questionnaires, transcripts, codebooks, audio recordings, video recordings, images, films, protein or genetic sequences, spectra, test responses, slides, artifacts, specimens, samples, collection of digital objects acquired and generated during the process of research, database contents (quantities and codes, text, video, audio, images, or other data objects), models, algorithms, scripts, contents of an application (input, output, logfiles for analysis software, simulation software, schemas), methodologies and workflows, standard operating procedures and protocols.  

 IV. Ownership  

In accordance with the UI’s Copyright Policy, the UI generally owns the Research Data generated from all Research, development, and related activities conducted under its oversight. The UI does not in this policy or in the Copyright Policy generally claim ownership of copyright in scholarly journal articles or other similar works       created by UI academic authors based on such Research Data.  The UI’s ownership of Research Data is derived in part from its role as a steward of public resources and extends from the UI’s obligation to be legally and financially accountable for issues related to Research Data. UI’s legal and financial obligations include the responsibility: • to investigate allegations of research misconduct;  • to protect the right of Investigators to access Research Data they collect; to ensure appropriate protections for human and animal subjects in Research;  • to secure and protect intellectual property rights; and  • to comply with the terms of sponsored Research agreements.  

V. Rights and Responsibilities  

On behalf of the UI, the Principal Investigator (PI) is the custodian of the Research Data and is ultimately responsible for the collection, management, and retention of Research Data. However, because other members of the Research team may have obligations for Research Data collection and retention, this policy uses the term “Investigator” to refer to all such team members.

 A.  Collection and Retention  

Investigators are responsible for the orderly collection, retention, organization, description, proper storage, and security of Research Data. Investigators will also ensure retention of complete records to document the methods used; accuracy of the Research Data collected and interpreted; and compliance with contractual agreements and UI requirements, including appropriate protections for human and animal subjects in Research, safeguards for protecting privacy and confidentiality of human Research subjects, proprietary information, and information controlled by law or regulation.   Research Data must be retained for a minimum of six years if the study involved the collection of protected health information (as defined by HIPAA). For all other Research, Research Data must be retained for a minimum of five years after the final closeout of the funded project or resulting publication, whichever occurs later. Circumstances that may require that Research Data be kept for a longer period: include, but are not limited to, investigation of allegations regarding the integrity of Research, preservation of intellectual property rights, completion of Research Data Policy  Jan. 12, 2017; Rev.  April 14,2023 3  student graduation requirements, and requirements imposed by the federal government or Research sponsors.   Whenever possible, the original Research Data must be part of the Research Data records. Research Data will ordinarily be stored in the PI’s lab or the unit where the records were created, but in any event, in storage locations (physical or electronic) owned or managed by the      UI and consistent with any contractual agreements or applicable laws and regulations.  When required by laws, regulations, or other agreements, Investigators must destroy Research Data on or before a specified deadline and follow the applicable process for destroying Research Data.   UI requirements related to institutional data and data security are described in the Institutional Data Policy  and IT Security Policy respectively.  

B.  Access  

As owner of the Research Data, the UI has the right to access the original Research Data to ensure that UI meets its obligations of legal and financial accountability for the Research Data. PI(s) will provide access to Research Data to the UI upon reasonable request (e.g., duly designated research compliance staff needing access to Research Data in performance of oversight/investigation duties. PI(s) will also provide access to authorized representatives of extramural sponsors of the Research, to designated governmental officials, or to accrediting organizations where such access is deemed appropriate by the UI.   The PI will facilitate requests for access to Research Data by members of the Research team who were involved significantly in the design, conduct, or reporting of the Research Data.  

C.  Sharing of Research Data  

Unless otherwise controlled or restricted, Research Data should be shared upon request for non-commercial purposes in accordance with data sharing policies adopted by federal agencies or other funding sponsors. The PI is responsible for following the requirements imposed by any sponsors of Research and, as applicable, the informed consent document and conditions of Institutional Review Board (IRB) approval.  

D. Data Restrictions  

UI is subject to regulatory requirements that affect the acquisition and protection of Research Data. UI complies with all applicable agency policies and makes Research Data available as broadly as possible while also providing protection to data collected or acquired in the planning or conduct of Research that is specifically restricted or controlled under Federal laws and regulations.  

VI. Transfer of Research Data – Investigator Departure  

An Investigator who leaves the UI may request to transfer copies of Research Data for any part of a project in which they were significantly involved in the design, conduct, or reporting of Research. Prior to leaving the UI, the Investigator shall identify in writing to their departmental executive officer (or equivalent person) those Research Data records they have Research Data Policy  Jan. 12, 2017; Rev.  April 14,2023 4  in their custody at the time and those Research Data records the Investigator wishes to copy and transfer to the new institution.    The transfer of copies of Research Data to a new institution is subject to UI approval and may be restricted by the need to protect proprietary rights, by contractual confidentiality obligations, or as restricted by law (e.g., HIPAA) or regulation.   UI approval of a request to transfer copies of Research Data will be granted upon a written agreement between the UI and the Investigator’s new institution in which the new institution accepts custodial responsibilities for the Research Data and, if applicable, agrees to obtain its own IRB approval prior to using identifiable human subjects Research Data collected at UI.  Upon approval by the UI, and unless otherwise restricted as described above, the UI will provide the requested copies of the Research Data to the departing Investigator within a reasonable amount of time after the request. Any costs associated with the transfer of copies of Research Data shall be the responsibility of the departing Investigator or the new institution.  

Original Research Data  

Original Research Data may not be transferred to a new institution or otherwise removed from the UI without the express prior written approval of the Investigator’s departmental executive officer (or equivalent person). If the original Research Data has been collected while conducting human subjects research, the UI IRB must review and approve the transfer prior to approval. If the original Research Data is being transferred to a new institution, the new institution must accept custodial responsibility for the data and agree in writing to provide the UI with access to the original Research Data as necessary.  

VII. Dispute Resolution  

Any disputes arising under this policy, including disputes regarding requests to transfer copies of Research Data or original Research Data, shall be resolved by the Vice President for Research.  

Other University of Iowa Policies Related to Research Data    

Institutional Data Policy  https://itsecurity.uiowa.edu/institutional-data  

IT Security Policy  https://itsecurity.uiowa.edu/security-policy