Policies & Compliance

Award Management

Records Retention

Accurate research records are an essential component of any research project. Both the University and the PI have responsibilities and rights concerning access to, use of, and maintenance of original research data* regardless of the source of funding for the project. Except where precluded by the specific terms of a sponsored agreement, tangible research property, including the scientific data and other records of research conducted by the faculty or staff of the University, belongs to the University.

*Research Data: includes laboratory notebooks, as well as any other records that are necessary for the reconstruction and evaluation of reported results of research and the events and processes leading to those results, regardless of the form or the media on which they may be recorded.

9.9.1 University Ownership and Responsibilities

The University of Utah retains ownership and stewardship of the scientific data and records for projects conducted at the University or that use University personnel or resources. The University's oversight responsibilities are based on regulations including OMB A-110 Sec. 53 and good management practices.

The University's responsibilities include:

Complying with the terms of sponsored project agreements
Ensuring appropriate use of animals, human subjects, recombinant DNA, etiological agents, radioactive materials, etc.
Protecting the rights of students, postdoctoral scholars, and staff, including, but not limited to, their rights to access data from research in which they participated and their rights to publish the results of such research
Protecting and securing intellectual property rights
Facilitating the investigation of charges, such as scientific misconduct or conflict of interest
Complying with audit requests for information
Providing sponsors with timely and appropriate reports as required by the Sponsor's agreement or regulations
Responding to Utah Governmental Records and Access Management Act (GRAMA) or Freedom of Information Act (FOIA) requests for information as directed by the University Office of General Counsel

9.9.2 Principal Investigators Responsibilities

The PI is responsible for the collection, management, maintenance and retention of research data accumulated under a research project. The University must retain research data in sufficient detail and for an adequate period of time to enable appropriate responses to questions about accuracy, authenticity, privacy and compliance with laws and regulations governing the conduct of the research. It is the PI's responsibility to determine what records need to be retained to comply with Sponsor requirements. PIs should adopt an orderly system of data organization and should communicate the chosen system to all members of a research group and to the appropriate administrative personnel, where applicable. Particularly for long-term research projects, PIs should establish and maintain procedures for protection of essential records in the event of a natural disaster or other emergency.

9.9.3 Duration of Retention of Data

Research data must be archived for a minimum of three years after the final project closeout, with original data retained wherever possible. Some sponsors require a longer period of retention.

Some circumstances may require a longer period of retention such as:

Data that must be kept for as long as necessary to protect intellectual property and complete patenting and licensing procedures for inventions resulting from the work;
If any charges regarding the research arise, such as allegations of scientific misconduct, conflict of interest, or allocable and allowable costs, data must be retained until such charges are fully resolved;
Data must be kept on campus for three years (FOIA) even if placed in a research data repository such as The Hive (University of Utah research data repository) or any subject-based data repository;
If a student is involved in the research, data must be retained at least until the student's degree is awarded or it is clear that the student has abandoned work on the project.

9.9.4 Access to Records

Records will normally be retained in the department where they are produced. Research records must be retained on the University of Utah campus, or in facilities leased or maintained by the University of Utah unless the Vice President for Research or the Director of OSP grants specific permission to do otherwise. The PI should develop appropriate procedures for proper archiving and tracking of research data. Sewn or otherwise permanently bound laboratory books are required for pursuit of patents.

Where necessary to assure needed and appropriate access, the University has the option to take custody of the data in a manner specified by University policy.

9.9.5 Transfer of Data or Records When a Researcher Leaves the University

When individuals involved in research projects leave the University, they may take copies of research data for projects on which they have worked unless a sponsor has retained the rights to such data, or the data or records are proprietary and/or confidential in nature. The PI must retain all original records at the University of Utah.

If a PI leaves the University, and the research project is going to be transferred to another institution, ownership of the data may be transferred with the approval of the sponsor and the Vice President for Research. The PI's department should retain a copy of all records regarding the research completed at Utah in the event of an audit or other request. The PI's new institution must accept and agree to take custodial responsibilities for the transferred data and must grant the University of Utah access to the original data should it be necessary.

If a PI leaves the University and the research project will remain at the University of Utah, a new PI will be assigned to take responsibility for all original records retained at the University.

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