Office of the Vice President for Research has oversight of the policy. Last updated October 14, 2026.

1. 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, contractual agreements, institutional policies, and sound management principles to ensure:

• alignment with the UI mission; 
• compliance with UI Research Security Program policies and guidelines;
• 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. 

2. 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. It shall apply to all research projects on which those individuals work, including collaborative research conducted with external institutions or investigators, regardless of the type of research, the source of support for the project, or whether the research data are analyzed, published, or otherwise disseminated.

3. Definitions 

“Collaborator” means any individual or entity that works jointly with a principal investigator or research team to contribute unique expertise, resources, or effort to a scientific or scholarly project.

“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, regardless of funding source. 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 the design, conduct, and reporting of Research at or under the oversight of UI. 

“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 validate research findings.

Examples of Research Data include, but are not limited to: documents, spreadsheets, databases, laboratory notebooks, field notebooks, diaries, questionnaires, surveys, 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. 

“Original Research Data” means the primary or authoritative Research Data and associated documentation maintained as the University’s record of the Research and necessary to document, substantiate, or verify the conduct and findings of the Research. Original Research Data may exist in physical or electronic form and does not include copies made solely for convenience, reference, or authorized sharing.

“Research Record” means the record of the Research Data or results that embody the facts resulting from scientific inquiry. Research Data or results may be in physical or electronic form. Examples of items, materials, or information that may be considered part of the Research Record include, but are not limited to, research proposals, raw data, processed data, clinical research records, laboratory records, study records, laboratory notebooks, progress reports, draft or completed manuscripts or other written materials, abstracts, theses, lab meeting reports, journal articles, images, recordings, online content, and records of oral presentations, including presentation slides and other materials used to communicate research findings.

4. Ownership

The UI generally owns the Research Data generated from all Research, development, and related activities conducted under its oversight. UI does not, in this policy or in the Copyright Policy, generally claim ownership of copyright in scholarly journal articles, theses, or other similar works created by UI academic authors based on such Research Data.

As a steward of public resources, UI’s ownership of Research Data reflects the legal, financial, and regulatory responsibilities for the management and protection of Research Data. UI’s obligations include the responsibility to:

• interpret and implement applicable federal, state, sponsor and institutional requirements governing Research Data;
• investigate allegations of research misconduct; 
• protect the right of Investigators and other authorized members of the research team to access and publish Research Data consistent with applicable laws, contractual agreements, and institutional policies;
• ensure appropriate protections for human and animal subjects in research; 
• secure and protect intellectual property rights consistent with the UI intellectual property policy; 
• comply with the terms and conditions of sponsored awards, agreements, and other applicable legal and contractual requirements; 
• protect Research Data from unauthorized access, disclosure or use in accordance with applicable research security requirements and University policy; and
• preserve Research Data and the Research Record as necessary to support research integrity, institutional accountability, and verification of research findings.

5. Rights and Responsibilities

The Office of the Vice President for Research (OVPR) is responsible for establishing and administering institutional requirements governing the collection, management, access, sharing, transfer, retention, and protection of Research Data. In carrying out these responsibilities, the OVPR interprets and implements applicable legal, contractual, and institutional requirements governing Research Data and the Research Record.

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

Investigators must also comply with UI requirements related to institutional data and data security, including the Institutional Data Policy,  IT Security Policy, and the International Travel Guidelines.  Investigators are prohibited from inputting any Research Data into an externally sourced artificial intelligence (AI) tool or service unless approved by ITS. 

1.  Collection, Storage, and Retention

Investigators are responsible for the orderly collection, retention, organization, description, proper storage, and security of Research Data. Investigators must also ensure retention of complete records to document the methods used; accuracy and integrity of the Research Data collected and interpreted; and compliance with laws, contractual agreements and institutional 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. 

Retention   Research Data must be retained as follows:

• Research involving Protected Health Information (PHI) as defined by the Health Insurance Portability and Accountability Act (HIPAA) must be retained for a minimum of six years.
• 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 Research Data or Research Records to be kept for a longer period include, but are not limited to:

• investigation of allegations regarding the integrity of Research; 
• pending or reasonably anticipated litigation, investigations, audits, or public records requests;
• preservation of intellectual property rights; 
• completion of student graduation requirements; and
• requirements imposed by the federal government or research sponsors. 

 Storage  Research Data and the Research Record must be stored securely on University of Iowa-owned or managed devices, systems, or storage services appropriate to the sensitivity and classification of the data. Physical Research Data must be maintained in University facilities or other approved locations under the control of the University. Whenever possible, the Original Research Data must be retained as part of the Research Record.  Storage of Research Data and the Research Record must be consistent with any applicable laws, contractual agreements and institutional policies, including applicable information security requirements.

Investigators must comply with applicable laws, contractual agreements and institutional policies on the timeline and process for destroying Research Data and Research Records.

2.  Access

As owner of the Research Data, the UI retains the right to access the Original Research Data to ensure that UI meets its obligations of legal and financial accountability for the Research Data. The PI(s) must provide access to Research Data and Research Record to the UI upon reasonable request (e.g., duly designated research compliance staff needing access in performance of oversight/investigation duties). The PI(s) must 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(s) is responsible for facilitating appropriate access to Research Data by members of the Research team who are significantly involved in the design, conduct, or reporting of the research, consistent with applicable laws, contractual agreements, and institutional policies. If Research team members leave the institution, the PI(s) is responsible for ensuring the PI retains all Research Data and Research Record, including any copies, and that continued data sharing does not occur except through a data sharing agreement with UI. 

VI. Sharing and Transfer of Research Data

A. General Principles

Research Data may be shared or transferred outside the University of Iowa (UI) only with appropriate institutional review and approval and only for legitimate research, educational, or other appropriate purposes. The Principal Investigator (PI) is responsible for ensuring that any sharing or transfer of Research Data is appropriate, limited to that which is necessary to accomplish the intended purpose, and completed in accordance with applicable laws, contractual agreements, and institutional policies.

B. Institutional Review and Approval

Research Data may not be shared or transferred outside the University without all required institutional reviews and approvals. Such review shall consider applicable laws, contractual requirements,  institutional policies and any restrictions applicable to the Research Data.

If the Research Data were collected as part of human subjects research, the proposed sharing or transfer must also comply with conditions of the Institutional Review Board (IRB) approval and informed consent documents.

Research Data that are subject to restrictions, including but not limited to proprietary information, confidentiality obligations, or data protected under law, may only be shared in a manner consistent with those restrictions.

C. Agreements and Documentation

Sharing or transfer of Research Data outside the University of Iowa is permitted only with an appropriate written agreement (e.g., research agreement, sponsored award, Data Use Agreement or other institutional agreement). Such agreements should address appropriate access, permitted use, protection, retention, and disposition of the Research Data and shall be consistent with applicable laws, contractual requirements, and institutional policies. Approval to transfer copies of Research Data does not transfer ownership of Research Data, which remains with UI unless otherwise provided by the written agreement.

Approvals, agreements, and other documentation associated with the sharing or transfer of Research Data shall be maintained in accordance with applicable University policies, contractual obligations, and institutional record retention requirements.

D. Security of Sharing and Transfer

Research Data must be shared or transferred using methods appropriate to the sensitivity and classification of the data and consistent with the UI IT Security Policy. Investigators are responsible for ensuring that appropriate safeguards are in place during transmission and that access to Research Data is limited to authorized individuals.

E. Original Research Data

Original Research Data shall remain in the custody of the University and may not be transferred to a new institution or otherwise removed from the UI without the prior written approval of the Investigator’s departmental executive officer (or equivalent person) and Dean, as documented through approval of the applicable routing form for the Data Use Agreement (DUA). Any such request shall be subject to the same considerations applicable to other transfers of Research Data, including legal, contractual, and institutional obligations.

Approval of any transfer of Original Research Data shall be limited to circumstances in which the receiving institution agrees in writing to assume appropriate custodial responsibilities and to provide the University reasonable access to the Original Research Data as necessary to fulfill the University’s legal, contractual, or institutional obligations. If the transfer is approved, a copy of the Original Research Data must be retained by the University.

F. Investigator Departure

When an Investigator leaves the UI, their department is responsible for maintaining all Research Data and the Research Record in accordance with the UI Records Management Program and Retention Schedule. An Investigator who leaves the UI may request to transfer copies of Research Data for any project in which they were significantly involved in the design, conduct, or reporting of the Research. Prior to departure, the Investigator shall provide a written request to their departmental executive officer (or equivalent person) identifying the Research Data in their custody and the copies of the Research Data they wish to transfer to a new institution.

The transfer of Research Data or Research Records in connection with an Investigator’s departure is subject to UI approval and may be restricted by proprietary rights, contractual obligations, or applicable laws. Approval of such a request requires an appropriate written agreement between the UI and the receiving institution.

Upon approval, and unless otherwise restricted, the UI will provide copies of the approved Research Data and Research Records within a reasonable period. Any costs associated with the preparation or transfer of such data shall be the responsibility of the departing Investigator or the new institution.

Dispute Resolution

Any disputes arising under this policy, including disputes regarding requests to transfer copies of Research Records, 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

Intellectual Property Policy  https://policy.uiowa.edu/administrative-financial-and-facilities-policies/university-iowa-intellectual-property-policy

Research Security Program Policy https://research.uiowa.edu/research-integrity-and-security-office/research-security/ui-research-security-program-policy

Records Management Policy https://policy.uiowa.edu/administrative-financial-and-facilities-policies/records-management

To request a DUA, submit a Non-monetary Routing Form to DSP, or email [email protected].

Data Use Agreements (DUAs) are contractual documents used for the transfer of non-public data that is subject to some restriction on its use. Broadly speaking, DUAs can be either Incoming (UI receives data from an outside entity) or Outgoing (data housed at UI are shared with an outside entity). 

Federal Demonstration Partnership (FDP)

The University of Iowa is a member institution of the Federal Demonstration Partnership (FDP) which utilizes FDP templates to share data for research between research institutions and hospitals. DSP encourages the use of FDP templates when possible. Using a FDP template typically shortens contract negotiation time to fall under the already negotiated template. 

Incoming DUAs

If you request to receive data from an outside institution or organization, it is the responsibility of that organization to determine whether a DUA should be executed prior sharing.  Some governmental organizations (Federal and State) have an application process that must be completed prior to the start of negotiations.  Please contact the appropriate UI office when starting this type of application process so that we can assist you with identifying and managing compliance issues. 

Outgoing DUAs

When data housed at the UI or collected by a UI student, staff, or faculty member is shared with an outside organization, the University must consider multiple security and compliance criteria. Outgoing DUAs are negotiated and signed by the office responsible for the particular dataset to be shared. While the UI maintains and uses several standard DUA templates, outgoing DUAs may need to be highly customized and therefore require additional time to negotiate.  Please allow for this by contacting the appropriate office for assistance well in advance of any related deadlines.

University of Iowa Partners in Data Management and Sharing

These UI offices have extensive experience in assisting researchers with grant proposals and research compliance, facilitating data management and sharing, and tracking the impacts of research. 

This policy for Data Management and Sharing places a strong emphasis on the sharing of scientific data to expedite the translation of research results into knowledge, products, and procedures to improve human health. Under the policy scientific data should be made accessible as soon as possible, and no later than the time of an associated publication, or the end of the performance period, whichever comes first.

The guidelines apply to all awards that generate scientific data regardless of funding mechanism. This includes:

• Grants
• Contracts
• Subgrants/Subcontracts
• Other transaction authority agreements (OTAs)

UI Research Data Services NIH Data Management and Sharing Plans Information pages

Tools for Creating a DMS Plan

Creating Data Management Plans with DMPTool

Educational Opportunities

UI Research Data Services offers on-demand training and consultations. 

• Request via form, contact page, or email

NIH Scientific Data Sharing website   

UI Research Data Services NSF Data Management and Sharing Plans

UI Research Data Services: Other Funders Data Management Plans